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{{#Wiki_filter:ATTACHMENT 11DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORTHREE MILE ISLAND NUCLEAR STATIONEP-AA-1 009Enclosures 000Enclosure 11 A -EAL Comparison Matrix DocumentEnclosure 11B -EAL Red-Line Basis DocumentEnclosure 11C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSATTACHMENT 11DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FORTHREE MILE ISLAND STATIONExelon Generation.
NEI 99-01 Rev 6 [Proposed EAL Justification AG1Initiating Condition
-GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mremTEDE or 5,000 mrem thyroid CDE.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.
* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.
* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
: 1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 1000 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than5000 mrem for one hour of inhalation.
RG1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1,000mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:
1,2,3.4,5,6,D Emergency Action Levels (EAL):Notes:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release pathto the environment is established.
If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15minutes.OR2. Dose assessment Using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate
> 5000 mRem CDEThyroid for 60 minutes of inhalation.
Table Ri Effluent Monitor Thresholds Effluent Monitor General Emergency RM-G-25 (Cond Offgas) 9.53 E+06 mR/hrRM-A-8GH (Station Vent) 3.09 E+05 cpmRM-G-24 (RB Purge) 5.55 E+05 mRPhrRM-A-14 (ESF Vent) 6.66 E+02 uCi/ccE No Change f Difference ElDeviation
: 1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
: 2) Added "Classification based on effluent monitor readings assumes that arelease path to the environment is established."
To the third bullet in order todelete the following from the basis section " Classification based on effluentmonitor readings assumes that a release path to the environment is established.
Ifthe effluent flow past an effluent monitor is known to have stopped due to actionsto isolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."
This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 11x17 procedure matrix used by the SM.Page 1 of 66 NEI 99-01 Rev 6 Proposed EAL j Justification AS1Initiating Condition
-SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mremTEDE or 500 mrem thyroid CDE.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptlyupon deterrining that the applicable time has been exceeded, or will likely beexceeded.
" if an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.
* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
: 1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 100 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than500 mrem for one hour of inhalation.
RS1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mRemTEDE or 500 mRem thyroid CDE.Operating Mode Applicability:
1,2,3,4,5,6,D Emergency Action Levels (EAL):D No Change E Difference 1 Deviation
: 1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
: 2) Added "Classification based on effluent monitor readings assumes that arelease path to the environment is established."
To the third bullet in order todelete the following from the basis section "Classification based on effluentmonitor readings assumes that a release path to the environment is established.
Ifthe effluent flow past an effluent monitor is known to have stopped due to actionsto isolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."
This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 1 1x17 procedure matrix used by the SM.Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established.
If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyondthe site boundary of EITHER:a. >100mRemTEDE ORb. > 500 mRem CDE ThyroidOR3.. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate
> 500 mRem CDEThyroid for 60 minutes of inhalation.
ITable R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency RM-G-25 (Cond Offgas) 9.53 E+05 mR/hrRM-A-8GH (Station Vent) 3.09 E+04 cpmRM-G-24 (RB Purge) 5.55 E+04 mR/hrRM-A-14 (ESF Vent) 6.66 E+01 uCi/ccPage 2 of 66 NEI 99-01 Rev 6 ] Proposed EAL ] Justification AA1Initiating Condition
-ALERTRelease of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped dueto actions to isolate the release path, then the effluent monitor reading isno longer valid for classification purposes.
* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from adose assessment using actual meteorology are available.
: 1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site-specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 10mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Analysis of'a liquid effluent sample indicates a concentration orrelease rate that would result in doses greater than 10 mrem TEDEor 50 mrem thyroid CDE at or beyond (site-specific dose receptorpoint) for one hour of exposure.
: 4. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than50 mrem for one hour of inhalation.
RA1Initiating Condition:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:
1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note:* The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
* If an ongoing release is detected and the release start time is unknown, assumethat the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a releasepath to the environment is established.
If the effluent flow past an effluentmonitor is known to have stopped due to actions to isolate the release path, thenthe effluent monitor reading is no longer valid for classification purposes.
* The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment using actual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 60 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 60 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for >360 minutes.ORb. Analyses of field survey samples indicate a 60 mRem CDEThyroid for 60 minutes of inhalation.
Table R1 Effluent Monitor Thresholds Effluent Monitor AlertRM-G-25 (Cond Offgas) 9.53 E+04 mR/hrRM-A-8GH (Station Vent) 3.09 E+03 cpmRM-G-24 (RB Purge) 5.55 E+03 mR/hrRM-A-14 (ESF Vent) 6.66 E+00 uCi/ccH:1 No Change E Difference
-I- Deviation
: 1) Listed site-specific monitors and Threshold values to ensure timely classification.
: 2) Added "Classification based on effluent monitor readings assumes that a releasepath to the environment is established."
To the third bullet in order to delete thefollowing from the basis section "Classification based on effluent monitor readingsassumes that a release path to the environment is established.
If the effluent flowpast an effluent monitor is known to have stopped due to actions to isolate therelease path, then the effluent monitor reading is no longer valid for classification purposes."
This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 11x17 procedure matrix used by the SM.3) Calculations were performed, in accordance with (lA) guidance provided in NEI99-01 revision 6 EAL AA1, to determine the effluent monitor response for aradioactive liquid release and a WGDT release via the normal site release pathway.The release would contain activity equivalent to provide 10mrem TEDE or 50mremthyroid CDE at the site boundary.
The calculation determined the effluent monitorresponses would be >110% of the instruments maximum range and as such, lAWNEI 99-01 Rev 6 guidance, was not included in this EAL.Page 3 of 66 0NEI 99-01 Rev 6 Proposed EAL IJustification AU1Initiating Condition
-UNUSUAL EVENTRelease of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longerOperating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert promptly upondetermining that 60 minutes has been exceeded, or will likely beexceeded.
* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 60 minutes.* If the effluent flow past an effluent monitor is known to have stopped,indicating that the release path is isolated, the effluent monitor reading isno longer valid for classification purposes.
: 1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for"60 minutes orlonger:(site-specific monitor list and threshold values corresponding to 2 timesthe controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times thealarm setpoint established by a current radioactivity discharge permit for60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent releasecontrolling document limits) for 60 minutes or longer.RU1Initiating Condition:
Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for60 minutes or longer.Operating Mode Applicability:
1, 2, 3,4,5, 6, DEmergency Action Levels (EAL):Note:* The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
* If an ongoing release is detected andthe release start time is unknown,assume that the release duration has exceeded 60 minutes.* Classification based on effluent monitor readings assumes that a releasepath to the environment is established.
If the effluent flow past an effluentmonitor is known to have stopped due to actions to isolate the release path,then the effluent monitor reading is no longer valid for classification purposes.
: 1. Reading on ANY of the following effluent monitors
> 2 times alarmsetpoint established by a current radioactive release discharge permitfor a 60 minutes.* RM-L-6, Radwaste Discharge
* RM-L-12, IWTS I IWFS Discharge
* RM-A-7, Waste Gas Decay Tank Discharge
* Discharge Permit specified monitorOR2. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60minutes.OR3. Confirmed sample analyses for gaseous or liquid releases indicateconcentrations or release rates > 2 times ODCM Limit with a releaseduration of Z 60 minutes.Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual EvetRM-G-25 (Cond Offgas) 1.09 E+03 mRlhrRM-A-8GH (Station Vent) 7.03 E+01 cpmRM-G-24 (RB Purge) 6.34 E+01 mR/hrRM-A-14 (ESF Vent) 7.60 E-02 uCi/cc1-No ChangeM Difference I Deviation
: 1) Listed site-specific monitors and Threshold values to ensure timely classification.
: 2) Added "Classification based on effluent monitor readings assumes that a releasepath to the environment is established."
To the third bullet in order to delete thefollowing from the basis section "Classification based on effluent monitor readingsassumes that a release path to the environment is established.
If the effluent flowpast an effluent monitor is known to have stopped due to actions to isolate therelease path, then the effluent monitor reading is no longer valid for classification purposes."
This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.Page 4 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AG2Initiating Condition
-- GENERAL EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.Operating Mode Applicability:
AllExample Emergency Action Levels:NOTES: The Emergency Director should declare the General Emergency promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded1. Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.RG2D No Change E Difference 1 Deviation
: 1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation
: Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard forReliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedOctober 25,2012.Page 5 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification AS2Initiating Condition
-SITE AREA EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3description)
Operating Mode Applicability:
AllExample Emergency Action Levels:1 Spent fuel pool level cannot be restored to at least (site-specific Level 3description)
RS2D No ChangeFI- Difference 1 Deviation
: 1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation
: Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard forReliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051) datedOctober 25,2012.Page 6 of 66 NEI 99-01 Rev 6 1Proposed EAL I Justification AAZInitiating Condition
-ALERTSignificant towering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2 or 3)1. Uncovery of irradiated fuel in the REFUELING PATHWAY.2. Damage to irradiated fuel resulting in a release of radioactivity from thefuel as indicated by ANY of the following radiation monitors:
(nite-specific listing of radiation
: monitors, and the associated
: readings, setpoints and/or alarms)3. Lowering of spent fuel pool level to (site-specific Level 2 value).RA2Initiating Condition:
Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:
1, 2, 3, 4, 5, 6,DEmergency Action Levels (EAL):1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuelas indicated by ANY Table R1 Radiation Monitor reading >1000 mRem/hrD- No Change E Difference 1 Deviation
: 1) Listed site-specific monitors and Threshold values to ensure timely classification.
: 2) EAL #3 not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation
: Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard forReliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedOctober 25,2012.Table R2Radiation MonitorsRMS Area Monitored ModeALLRM-G-9 FHB Bridge Rad Monitor5,6RM-G-6 RB Auxiliary Bridge Rad Monitor5,6RM-G-7 RB Main Bridge Rad MonitorPage 7 of 66 NEI 99-01 Rev 6 = Proposed EAL I Justification AU2Initiating Condition:
UNUSUAL EVENTUNPLANNED loss of water level above irradiated fuelOperating Mode Applicability:
AllExample Emergency Action Levels:1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
(site-specific level indications).
ANDb. UNPLANNED rise in area radiation levels as indicated by ANY of thefollowing radiation monitors.
(site-specific list of area radiation monitors)
RU2Initiating Condition:
UNPLANNED loss of water level above irradiated fuelOperating Mode Applicability:
1,2, 3,4,5, 6, DEmergency Action Levels (EAL):I. a. UNPLANNED water level drop in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.No Change 1:1 Difference F Deviation
: 1) Listed site-specific level indication and monitors to ensure timely classification.
Table R2Radiation MonitorsRMS Area Monitored ModeALLRM-G-9 FHB Bridge Rad Monitor5,6RM-G-6 RB Auxiliary Bridge Rad Monitor5,6RM-G-7 RB Main Bridge Rad MonitorPage 8 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification AA3Initiating Condition
-ALERTRadiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.
Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2)Note: If the equipment in the listed room or area was already inoperable, or outof service, before the event occurred, then no emergency classification iswarranted 1 Dose rite greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)
: 2. An UNPLANNED event results in radiation levels that prevent orsignificantly impede access to any of the following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)
RA3Initiating Condition:
Radiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.
Operating Mode Applicability:
1,2, 3, 4, 5. 6,DEmergency Action Levels (EAL):Note: If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification iswarranted
: 1. Dose rate greater than 15 mR/hr in ANY of the areas contained in Table R3:E No Change 1 Difference Deviation
: 1) Listed site specific plant rooms and areas with identified mode applicability toensure timely classification.
OR2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R4 plant rooms or areas:Table R4Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 4, 5, and 6Intermediate Building*
Modes 4, 5, and 6Auxiliary Building*
Modes 4, 5, and 6Fuel Handling Building*
Modes 4, 5, and 6*Areas required to establish shutdown coolingPage 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU3Initiating Condition:
UNUSUAL EVENTReactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:1. (Site-specific radiation monitor) reading greater than (site-specific value).OR2. Sample analysis indicates that a reactor coolant activity value is greater thanan allowable limit specified in Technical Specifications.
RU3Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):1. Letdown Monitor RM-L-1 alert alanm (high or low channel).
OR2. Sample analysis indicates that:a. Dose Equivalent 1-131 specific coolant activity
> 60.0 uCilgm.ORb. Dose Equivalent XE-1 33 specific coolant activity> 797.0 uCi/gm.-- No Change M Difference F Deviation
: 1) Listed site-specific monitor and threshold value to ensure timely classification.
: 2) Listed this system category EAL in the radiological category EAL section tomaintain consistency with current and previous revisions of Exelon EALs. This willensure a timely classification since the threshold values are more aligned with theradiological category vice system category.
Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier MatrixFGt Loss of any two barriers AND Loss or Potential Loss of third bamer. 1.2,3,4 FS1 Loss or Potential Loss of ANY two bamers. 1.2.3.4 FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1.2.3,4FC -Fuel C lad RC -Reactor Coolant System CT -Containment Lub-Category Loss Potential Loss Loss Potential Loss Loss Potential LossA. Operation of a standby charging(makeup) pump is required by EITHER ofA. An automatic or manual ECCS (SI) the following:
A actuation is required by EITHER of the a UNISOLABLE RCS leakageA. RCSlreactor vessel level less OR1. RCS or SG None than (site-specific level). following:
: b. SG tube leakage.
A leaking or RUPTURED SG is NoneTube Leakage a. UNISOLABLE RCS leakage OR FAULTED outside of containment.
OR B. RCS cooldown rate greater thanb. SG tube RUPTURE.
(site specific pressurized thermalshock criteriallimits defined by sitespecific Indications)
A. Core exit thermocouple readingsgreater than (site specific A. 1. (site specific criteria for entry intoA. Core exit thermocouple temperature value) A. Inadequate RCS heat removal core cooling restoration procedure)
: 2. Inadequate readings greater than (site OR None capability via steam generatore as None ANDHeat Removal specific temperature value) B. Inadequate RCS heat removal indicated by (site specific Indications).
: 2. Functional Restoration Procedures capability via steam generators not effective in < 15 minutes.as indicated by (site specificindications).
A, Containment radiation monitorreading greater than (site specific3 RCS Activity/
value) A. Containment radiation monitor A. Containment radiation monitor readingContainment OR None reading greater than (site specific value) None None greater than (she specific value)Radiation B, (Site specific indications that reactorcoolant activity is greater than 300uCi/gm dose equivalent 1-131).A.Containment isolation is required AND A. Containment pressure greater than (siteEITHER of the following:
specific value)1. Containment integrity has been ORlost based on Emergency Director B. Explosive mixture exists insidejudgement.
containment.
4.Containment OR ORIntegrity or None None None NoneBypass 2. UNISOLABLE pathway from C. 1. Containment pressure greater thancontainment to the environment (site specific value)exists. ANDOR 2. Less than one full train of (siteB Indication of RCS leakage outside of specific equipment) is operating containment per design for _15 minutes.A, Any Condition in the opinion of the A. Any condition in the opinion of the A. ANY Condition in the opinion ot the A. Any Condition in the opieonof the A. Any Condition in the opinion of the A. Any Conditon in the opinion of the Emergency
: 5. Emergency n Emergency Director that indicates Loss mergecy Director that indicates Potential Emergeecy Director thar indicates Lose at Emergency Director tsar indicates Potential Emergency Director tsar idicates Loss ot the Director that indicates Potential Loss of theDirector Judgment of the Fuel Clad Barier. Loss of the Fuel Clad Barner. the RCS Barmer. Loss of the RCS Bamer. Containment Barrier.
Containment Barrer.Page II of 66 Proposed Fission Product Barrier MatdxFG1 Loss of any Iwo banriors AND Loss or Potential Loss of third barrier.
FBI Loss or Potential Loss of ANY two barrers.
[fE [ FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS OEMi~iFC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category, Loss Potential Loss Loss Potential Loss Loss Potential Loss2. UNISOLABLE RCS leakage >159gpm.1. RCITS hot leg instruments indicate
: 1. Automatic or manual ESAS adtuation is OR0 inches after lowering trend, required by EITHER of the following:
AND a. UNISOLABLE RCS leakage 3. HPI-PDRV Cooling in elfect. l e >b LRCS or Sg None 2. In-core thermocouples are unavailable.
OR OR 2. SG is FAULTED outside of containment.
NoneTube Leakage AND b. Steam Generator tube 4. a. RCS Pressure a 2450 psig.3. ALL RCP's are secured.
RUPTURE.ANDb. RCS Pressure not lowering1. T_ a _ 1800iF.2. > 25"F Superheat AND2. Inadequate
: 1. T > 14001F OR None None 2. EOP Restoration procedures notHeat Removal 3. HPF-PORV Cooling in effect. HPI-PORV Cooling in effect. effective ine< 1 minutes.1. Containment radiation monitor (RM-G-22 or RM-G-23) reading > 1.95E+033. Containment R/hr. Containment radiation monitor (RM-G-22 or Containment radiation monitor (RM*G-22 orRadiation
/ RCS OR None RM-G-23) reading > 25 Rlhr. None None RM-G-23) reading > 4.40E+03 R/hr oAdivity 2. Coolant activity
> 300uCi/gm DoseEquivalent 1-1313. Reactor Building Pressure
> 55 psig1. Containment isolation is required and and rising.EITHER of the following:
ORa. UNPLANNED lowering in 4. Hydrogen Concentration incontainment pressure or rise in Containment a 4%.radiation monitor readings ORoutside of containment in the 5. a. Reactor Budding pressureEmergency Directors judgment 30 psigindicate a loss of containment
: 4. Containment None None None None integrity.
ANDIntegnty or Bypass OR b. Reactor Building Emergency
: b. UNIODLABLE pathway frow cooling is less than ANY one of thecontainment to the f cniosenvironment exists.OR SPRAY COOLERS2. Indication of RCS leakage outside of 2 0containment 0 31 15. Emergency
: 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of theDirector Judgment Emergency Director that indicates Emergency Director that indicates Emergency Director that indicates Emergency Director that indicates Emergency Diredtor that indicates Potential Loss el te Containment Loss of the Fuel Clad Bater. Potential Loss of the Fuel Clad Barrier.
Loss of the RCS Baoer. Potential Loss of the RCS Bater. Loss of the Containment Baoier. Boatrer.Page 12 of 66 NEI 99-01 Rev 6 Proposed EAL Justification F~l[F, jJ- No Change [j Difference Li Deviation Category:
Fuel Clad Barrier Category:
Fuel Clad BarrierRCS or SG tube leakage RCS or SG tube leakage 1) Listed site-specific threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot Shutdown 1,2, 3,4Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Potential Loss Potential LossA. RCS/reactor vessel level less than (site-specific level). 1. RCITS hot leg instruments indicate 0 inches after lowering trend.AND2. In-core thermocouples are unavailable.
AND3. ALL RCP's are secured.Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Fuel Clad Barrier FC2 Category:
Fuel Clad BarrierC2 No Change D Difference Deviation Inadequate Heat Removal RCS Activity
: 1) Listed site-specific threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
: 2) Potential Loss #3, The initiation of HPI -PORV cooling creates a controlled Power Operation,
: Startup, Hot Standby, Hot Shutdown 1,2, 3, 4 opening of the RCS to the RB by an open PORV. This is indicative of the steamFission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
generators inability to remove heat from the RCS and represents a potential challenge to the FC barrier and is considered a potential loss.Loss LossA. Core exit thermocouple readings greater than (site-specific temperature value). 1. Trad > 1400&deg;FPotential Loss Potential LossA. Core exit thermocouple readings greater than (site-specific temperature value). 2. > 25&deg;F Superheat OR ORB. Inadequate RCS heat removal capability via steam generators as indicated by 3. HPI-PORV Cooling in effect.(site-specific indications).
Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Fuel Clad Barrier FC3 Category:
Fuel Clad Barrier 'C3 E No Change Difference Deviation Containment Radiation
/ RCS Activity Containment Radiation
/ RCS Activity
: 1) Listed site-specific monitor and threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot Shutdown 1,2.3. 4Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss LossA. Containment radiation monitor reading greater than (site-specific value). 1. Containment radiation monitor (RM-G-22 or RM-G-23) readingOR > 1.95E+03 R/hr.ORB. (Site-specific indications that reactor coolant activity is greater than 300 iC[igm 2. Coolant activityR>
300uCigm Dose Equivalent 1-131dose equivalent 1-131).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Fuel Clad Barrier FC6 Category:
Fuel Clad Barrier FC5 No Change Differne Deviation Emergency Director Judgment Emergency Director JudgmentOperating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup.
Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Fuel Clad Barrier.
the Fuel Clad Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential
: 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC1 C1 [--]No Change [---- Difference Deviation Category:
Reactor Coolant System Barrier Category:
Reactor Coolant System BarrierRCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
: 2) Potential loss threshold
#2 is based on the inability to maintain normal liquidPower Operation,
: Startup, Hot Standby, Hot Shutdown 1,2, 3.4 inventory within the RCS by normal operation of the Make Up System, when oneFission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Make Up Pump is discharging to the charging header. The need for a secondMake Up Pump or the use of the high capacity makeup rate would be indicative ofLoss Loss a substantial RCS leak. 120 gpm is the nominal capacity of each Make Up Pump.However, 150 gpm (high makeup flow alarm setpoint) was selected because it isA. An automatic or manual ECCS (SI) actuation is required by EITHER of the 1. Automatic or manual ESAS actuation is required by EITHER of the following:
more easily recognized by the operator which will result in a more timelyfollowing:
: a. UNISOLABLE RCS leakage declaration than performing a calculation.
: 1. UNISOLABLE RCS leakage OROR b. Steam Generator tube RUPTURE.
: 2) Potential Loss #3, The initiation of HPI -PORV cooling creates a controlled
: 2. SG tube RUPTURE.
Potential Loss opening of the RCS to the RB by an open PORV. The opening of the RCS and thesPotential Loss pressure control mode through throttling of the HPI and or MU valves represents a2. UNISOLABLE RCS leakage > 150gpm. potential challenge to the RCS barrier and is considered a potential loss.A. Operation of a standby charging (makeup) pump is required by EITHER of the ORfollowing:
: 3) Potential Loss #4, The pressurizer code safety valves will open between 24501. UNISOLABLE RCS leakage 3. HPI-PORV Cooling in effect. psig and 2510 psig(allowance for set pressure and Code Safety valveOR OR accumulation).
This is the design limit for the RCS and well within tested values(2750 psig). If the RCS heatup is able to keep the pressurizer code safety valves2. SG tube leakage.
: 4. a. RCS Pressure
> 2450 psig. open with pressure either increasing or cycling then the RCS shall be considered aOR AND potential breach.B. RCS cooldown rate greater than (site-specific pressurized thermal shockcriteria/limits defined by site-specific indications).
: b. RCS Pressure not loweuing.
: 4) The proposed EAL provides the Operators with a clear and easily recognizable entry condition for this EAL without altering the intent of the EAL. The usage ofthe specified thresholds would ensure timely declaration should this event occur.TMI is using these conditions as entry into this EAL to mimic the concerns of thePotential Loss of RCS as shown in the Westinghouse CSFT monitoring forpressurized thermal shock (PTS) through the use of the RCS integrity red path.These are the same thresholds as what was approved in EArs based on NEI 99-01 Rev 5.Page 17 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Reactor Coolant System Barrier RC2 Category:
Reactor Coolant System BarrierRC2 No Change Difference Deviation Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
: 2) The initiation of HPI -PORV cooling creates a controlled opening of the RCS toPower Operation,
: Startup, Hot Standby, Hot Shutdown 1,2,3,4 the RB by an open PORVW The opening of the RCS and the pressure control modeFission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
through throttling of the HPI and or MU valves represents a potential challenge tothe RCS barrier and is considered a potential loss.Potential Loss Potential LossA. Inadequate RCS heat removal capability via steam generators as indicated by HPI-PORV Cooling in effect.(site-specific indications).
Page 18 of 66 NEI 99-01 Rev 6Proposed EALJustification 4 i-RC3Category:
Reactor Coolant System BarrierContainment Radiation I RCS ActivityOperating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:
LossA. Containment radiation monitor reading greater than (site-specific value).RC3Category:
Reactor Coolant System BarrierRCS Leak RateOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LossContainment radiation monitor (RM-G-22 or RM-G-23) reading > 25 RJhr.E No Change I Difference 1 Deviation
: 1) Listed site-specific systems and threshold values to ensure timely classification.
Page 19 of 66 NEt 99-01 Rev 6 Proposed EAL Justification Category:
Reactor Coolant System Barrier RC6 Category:
Reactor Coolant System Barrier RC5 No Change Difference Deviation Emergency Director Judgment Emergency director JudgmentOperating Mode Applicability:
Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot Shutdown 1,23,34Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss ofthe RCS Barrier.
the RCS Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
: 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Containment Barrier CT1 Category:
Containment Barrier No Change Diffe ce Deviation RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold values to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss LossA. A leaking or RUPTURED SG is FAULTED outside of containment.
: 1. SG tube leakage > 150gpmAND2. SG is FAULTED outside of containment.
Page 21 of66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6Proposed EALJustification i i +CT2Category:
Containment BarrierInadequate Heat RemovalOperating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:
Potential LossA. 1. (Site-specific criteria for entry into core cooling restoration procedure)
AND2. Restoration procedure not effective within 15 minutes.CT2Category:
Containment BarrierInadequate Heat RemovalOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
Potential Loss1. T.,&#xfd; > 1 800&deg;F.AND2. EOP Restoration procedures not effective in < 15 minutes.I--E No Change D: Difference 1:1 Deviation
: 1) Listed site-specific threshold values to ensure timely classification.
Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Containment Barrier CT3 Category:
Containment Barrier CT3 [ No Change Differce Deviation Containment Radiation
/ RCS Activity Containment Radiation
/ RCS Activity
: 1) Listed site-specific threshold values to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Potential Loss Potential LossA. Containment radiation monitor reading greater than (site-specific value). Containment radiation monitor (RM-G-22 or RM-G-23) reading > 4.40E+03 R/hr.Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CT4 CT4 -NChne Dfeee DeatoCategory:
Containment Barrier Category:
Containment Barrier C No Change Difference Deviation Containment Integrity or Bypass Containment Integrity or Bypass 1) Listed site-specific monitor and threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss LossA. Containment isolation is required
: 1. Containment isolation is required and EITHER of the following:
AND a. UNPLANNED lowering in containment pressure or rise in radiation monitorreadings outside of containment in the Emergency Directors judgmentEITHER of the following:
indicate a loss of containment integrity.
: 1. Containment integrity has been lost based on Emergency Director ORjudgment.
OR b. UNISOLABLE pathway from containment to the environment exists.2. UNISOLABLE pathway from the containment to the environment exists. OROR 2. Indication of RCS leakage outside of containment B. Indications of RCS leakage outside of containment.
Potential LossPotential Loss 3. Reactor Building Pressure
> 55 psig and rising.ORA. Containment pressure greater than (site-specific value) 4. Hydrogen Concentration in Containment
> 4%.OR ORB. Explosive mixture exists inside containment
: 5. a. Reactor Building pressure
> 30 psigOR ANDC. 1. Containment pressure greater than (site-specific pressure setpoint)
: b. Reactor Building Emergency cooling is less than ANY one of the following AND conditions:
: 2. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer. SPRAY COOLERS2 00 31 1Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Containment Barrier CT6 Category:
Containment BarriCerT5 No Change Difference Deviation Emergency director Judgment Emergency Director JudgmentOperating Mode Applicability:
Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Containment Barrier.
the Containment Barnier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential
: 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
Loss of the Containment Barrier.Page 25 of 66 0NEI 99-01 Rev 6 1 Proposed EAL I Justification SG1Initiating Condition:
GENERAL EMERGENCY Prolonged loss of all offsite and all onsite AC power to emergency buses.Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the General Emergency promptlyupon determining that (site-specific hours) has been exceeded, or willlikely be exceeded.
: 1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).ANDb. EITHER of the following:
" Restoration of at least one emergency bus in less than(site-specific hours) is not likely." (Site-specific indication of an inability to adequately remove heat from the core)MG1Initiating Condition:
Prolonged loss of all offsite and all onsite AC power to emergency buses.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. EITHER of the following:
: a. Restoration of at least one Emergency 4KV bus in < 4 hours is not likely.ORb. > 25&deg;F superheat F- No Change Difference Deviation
: 1) Listed site specific equipment, site specific time based on station blackoutcoping analysis, and site specific indication to ensure timely classification.
Page 26 of 66 0NEt 99-01 Rev 6 fProposed EAL Justification ss1Initiating Condition:
SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.
Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.MS1Initiating Condition:
Loss of all offsite and onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. Loss of ALL ofasite AC Power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutesfrom the time of loss of both offsite and onsite AC powerNo Change 1-1 Difference FIDeviation
: 1) Listed site specific equipment to ensure timely classification.
Page 27 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA1Initiating Condition:
ALERTLoss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely be exceeded.
: 1. a. AC power capability to (site-specific emergency buses) is reduced to a.single power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.MAIInitiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. AC power capability to Emergency 4KV buses reduced to only one of thefollowing power sources for > 15 minutes.* Auxiliary Transformer 1A* Auxiliary Transformer 1B* Emergency Diesel Generator EG-Y-1A* Emergency Diesel Generator EG-Y-1B* SBO Diesel Generator EG-Y-4AND2. Any additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.M No Change FIDifference I] Deviation
: 1) Listed site specific equipment to ensure timely classification.
.1 IPage 28 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification SulInitiating Condition:
UNUSUAL EVENTLoss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.
Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15minutes or longerMUlInitiating Condition:
Loss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
Loss of ALL offsite AC power capability to Emergency 4KV busses fora 15 minutes.I No Change FIDifference I Deviation
: 1) Listed site specific equipment to ensure timely classification.
Page 29 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SG8Initiating Condition:
GENERAL EMERGENCY Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:
Power Operation.
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the General Emergency promptlyupon determining that 15 minutes has been exceeded, or will likely beexceeded.
: 1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.ANDIndicated voltage is less than (site-specific bus voltage value) on ALL(site-specific vital DC busses) for 15 minutes or longer.MG2Initiating Condition:
Loss of all AC and Vital DC power sources for 15 minutes or longer:Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Voltage is < 105 VDC on 125 VDC Distribution System 1A and lB.AND4. ALL AC and Vital DC power sources have been lost for >_15 minutes.D- No Change M Difference
-IDeviation
: 1) Listed site specific voltage and equipment to ensure timely classification.
: 2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare,Page 30 of 66 NEI 99-01 Rev 6 JProposed EAL Justification b$8MS2Initiating Condition:
SITE AREA EMERGENCY Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:
D No ChangeI Difference
] Deviation Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, orwill likely be exceeded.
Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DCbuses for 15 minutes or longer.Initiating Condition:
Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
Voltage is < 105 VDC on 125 VDC Distribution System 1A and lB for>15 minutes.1) Listed site specific voltage and equipment to ensure timely classification.
: 2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 31 of`66 NEI 99-01 Rev 6 1 Proposed EAL I Justification SS5Initiating Condition:
SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPVwater level [BWR]) or RCS heat removal.Operating Mode Applicability:
Power Operation Example Emergency Action Levels:1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown thereactor.ANDb. All manual actions to shutdown the reactor have been unsuccessful.
ANDC. EITHER of the following conditions exist:1. (Site-specific indication of an inability to adequately remove heat from the core)OR2. (Site-specific indication of an inability to adequately remove heat from the RCS)MS3Initiating Condition:
Inability to shutdown the reactor causing a challenge to core cooling or RCS heatremoval.Operating Mode Applicability:
1.2Emergency Action Levels (EAL):1. Automatic or Manual Trip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. ALL manual actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 5%.AND3. EITHER of the following conditions exist:a. Tad > 1400&deg;F.ORb. HPI-PORV Cooling in effect.D- No Change F Difference
[IDeviation
: 1) Listed site specific indications to ensure timely classification.
: 2) Mode 2 included in operating mode applicability as per developer notes.3) The initiation of HPI -PORV cooling creates a controlled opening of the RCS tothe RB by an open PORV. This is indicative of the steam generators inability toremove heat from the RCS.Page 32 of 66 NEI 99-01 Rev 6Prpoe _AJustification NEt 99-01 Rev B Proposed EAL Justification iSA5Initiating Condition:
ALERTAutomatic or manual (trip [PWRJ / scram [BWRJ) fails to shutdown the reactor, andsubsequent manual actions taken at the reactor control consoles are notsuccessful in thutting down the reactor.Operating Mode Applicability:
Power Operation Example Emergency Action Levels:Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
: 1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown thereactor.ANDb. Manual action taken at the reactor control consoles are notsuccessful in shutting down the reactor.MA3Initiating Condition:
Automatic or manual trip fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting downthe reactor.Operating Mode Applicability:
1,2Emergency Action Levels (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
: 1. Automatic Trip did not shutdown the reactor as indicated by Reactor Power> 5%.AND2. Manual actions taken at the Console Center are not successful in shuttingdown the reactor as indicated by Reactor Power > 5%.F-1 No Change FIDifference 1 Deviation
: 1) Listed site specific indications to ensure timely classification.
: 2) Mode 2 included in operating mode applicability as per developer notes.Page 33 of 66 NEI 90-01 Rev 6 [Proposed EAL Justification SUSInitiating Condition:
UNUSUAL EVENTAutomatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:
Power Operation Example Emergency Action Levels: (1 or 2)Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
: 1. a. An automatic (trip [PWR] / scram [BWRI) did not shutdown thereactor.ANDb. A subsequent manual action taken at the reactor control consoles issuccessful in shutting down the reactor.2. a. A manual trip ([PWR] / scram [BWR]) did not shutdown the reactor.ANDb. EITHER of the following:
: 1. A subsequent manual action taken at the reactor control consolesis successful in shutting down the reactor.OR2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.MU3Initiating Condition:
Automatic or manual trip fails to shutdown the reactor.Operating Mode Applicability:
F- No Change I-1 Difference FIDeviation
: 1) Listed site specific indications to ensure timely classification.
: 2) Mode 2 included in operating mode applicability as per developer notes.1,2Emergency Action Levels (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
: 1. a. Automatic Trip did not shutdown the reactor as indicated by ReactorPower > 5%.ANDb. Subsequent manual action taken at the Console Center is successful inshutting down the reactor.OR2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power> 5%.ANDb. Subsequent automatic Trip is successful in shutting down the reactor.Page 34 of 66 NEI 99-01 Rev 6SA2Initiating Condition:
ALERTUNPLANNED lost, of Control Room indications for 15 minutes or longer with a significant transient in progress.
Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upon determining that15 minutes has been exceeded, or will likely be exceeded.
: 1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below]I BWR parameter list] I PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit Temperature Suppression Pool Level Levels in at least (site specific number)steam generators Steam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowANDb. Any of the following transient events in progress.
* Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical loadReactor Scram [BWR] / trp [PWR]* ECCS (SI) actuation
* Thermal power oscillations greater than 10% [BWR]Proposed EALJustification
-F +MA4Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.
Operating Mode Applicability:
1.2,23,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. a An UNPLANNED event results in the inability to monitor ANY Table M1parameters from within the Control Room for > 16 minutes.Table M1 Control Room Parameters
* Reactor Power* PZR Level* RCS Pressure* In Core/Core Exit Temperature
* Level in at least one OTSG.* OTSG Emergency Feed Water FlowANDb. ANY Table M2 transient in progress.
Table M2 Significant Transients
* Automatic Turbine Runback >25% thermal reactor power* Electrical Load Rejection
>26% full electrical load* Reactor Trip* ESAS Actuation
* Thermal Power oscillations
> 10%H No Change FIDifference
-IDeviation
: 1) Listed site specific number of steam generators to ensure timely classification.
Page 35 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SU2Initiating Condition:
UNUSUAL EVENTUNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.
An UNPLANNED event results in the inability to monitor one or more of thefollowing parameters from within the Control Room for 15 minutes or longer.[see table below][ BWR parameter list] [PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrmary Containment Pressure In Core/Core Exit Temperature nPool Level Levels in at least (site specificSuppression Pnumber) steam generators Steam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowMU4Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters
" Reactor Power" PZR Level* RCS Pressure* In Core/Core Exit Temperature
" Level in at least one OTSG." OTSG Emergency Feed Water FlowF No Change 1 Difference FI Deviation
: 1) Listed site specific number of steam generators to ensure timely classification.
Page 36 of 66 0NEI 99-01 Rev 6 Proposed EAL j Justification SA9Initiating Condition:
ALERTHazardous event affecting a SAFETY SYSTEM needed for the currentoperating mode.Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)
* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION
* (site-specific hazards)* Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:
: 1. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEM needed for thecurrent operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure needed for the current operating mode.MA5Initiating Condition:
ALERTHazardous event affecting a SAFETY SYSTEM required for the currentoperating mode.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)
* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION
* Other events with similar hazard characteristics asdetermined by the Shift ManagerAND2. EITHER of the following:
: a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by Technical Specifications for the current operating mode.F] No Change M Difference
[Deviation
: 1) No additional site specific hazards noted2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators andminimize confusion.
Page 37 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU4Initiating Condition:
UNUSUAL EVENTRCS leakage for 15 minutes or longer.Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.
: 1. RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer.2. RCS identified leakage greater than (site-specific value) for 15 minutes orlonger3. Leakage from the RCS to a location outside containment greater than 25gpm for 15 minutes or longerMU6Initiating Condition:
RCS leakage for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15minutesOR2. RCS identified leakage >25 gpm for > 15 minutesOR3. Leakage from the RCS to a location outside containment
>28 gpm for> 15 minutesNo Change 1 Difference FIDeviation
: 1) Listed site specific values to ensure timely classification.
Page 38 of 66 NEI 99-01 Rev 6 ] Proposed EAL I Justification SU6Initiating Condition:
UNUSUAL EVENTLoss of all onsite or offsite communications capabilities Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)MU7Initiating Condition:
Loss of all onsite or offsite communication capabilities.
Operating Mode Applicability:
1,2,3,4Emergency Action Levels (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting theability to perform routine operations.
OR2. Loss of ALL Table M3 Offsite communication capability affecting theability to perform offsite notifications.
OR3. Loss of ALL Table M3 NRC communication capability affecting the abilityto perform NRC notifications.
Table M3 Communications Capability System Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X XF No Change FIDifference
-IDeviation
: 1) Listed site specific communication methods to ensure timely classification.
Page 39 of 66 NEI 99-01 Rev 6 1 Proposed EAL [Justification SU7Initiating Condition:
UNUSUAL EVENTFailure to isolate containment or loss of containment pressure control.
[PWR]Operating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2)1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ALL required penetrations are not closed within 15 minutes of theactuation signal.2. a. Containment pressure greater than (site-specific pressure).
ANDb. Less than one full train of (site-specific system or equipment) isoperating per design for 15 minutes or longer.MU8Initiating Condition:
Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:
1,2.3,4Emergency Action Levels (EAL):1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ANY required penetration remains open > 15 minutes of the actuation signal.OR2. a. Reactor Building pressure
> 30 psigANDb. Reactor Building Emergency cooling is less than ANY one of thefollowing conditions for > 15 minutes:SPRAY COOLERS2 00 31 1FH No Change 1 -] Difference FIDeviation
: 1) Listed site specific indications to ensure timely classification.
: 2) Reworded EAL 1.b to be a positive statement Page 40 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA2Initiating Condition:
ALERTLoss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:
Cold Shutdown, Refueling, DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.
Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.CA1Initiating Condition:
Loss of all offsite and onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:
5,6, DEmergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
: 1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4SBO Diesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutesfrom the time of loss of both offsite and onsite AC power.E No Change 1 Difference 1 Deviation
: 1) Listed site specific equipment to ensure timely classification.
Page 41 of 66 NEt 99-01 Rev' S Proposed EAL Justification NEI 99-01 Rev6Proposed EALJustification
+ -tCU2Initiating Condition:
UNUSUAL EVENTLoss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
Cold Shutdown, Refueling.
DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely be exceeded.
: 1. a. AC power capability to (site-specific emergency buses) is reduced to asingle power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.CulInitiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes orlonger.Operating Mode Applicability:
5.6,0Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. AC power capability to Emergency 4KV buses reduced to only one of thefollowing power sources for > 15 minutes." Auxiliary Transformer 1A" Auxiliary Transformer 1 B" Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1B" SBO Diesel Generator EG-Y-4AND2. ANY additional single power source failure will result in a loss of ALL ACpower to SAFETY SYSTEMS.E No Change 1 Difference 1 Deviation
: 1) Listed site specific equipment to ensure timely classification.
Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA6Initiating Condition
-ALERTHazardous event affecting SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)
* Internal or external flooding event* High winds or tomado strike* FIRE" EXPLOSION
" (site-specific hazards)* Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:
: 1. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMneeded for the current operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure needed for the currentoperating mode.CA2Initiating Condition:
Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:
5,6Emergency Action Levels (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)
* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION
* Other events with similar hazard characteristics asdetermined by the Shift ManagerAND2. EITHER of the following:
: a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by Technical Specifications for the current operating mode.H No Change E Difference Deviation
: 1) No additional site specific hazards noted2) Changed the word "needed" to "required" in the IC and "required byTechnical Specification" in the EAL to be consistent with terminology used byoperators and minimize confusion.
Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU4Initiating Condition:
UNUSUAL EVENTLoss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.
Indicated voltage is less than (site-specific bus voltage value) on required Vital DCbuses for 15 minutes or longer.CU3Initiating Condition:
Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:
5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
Voltage is < 105 VOC on required 125 VDC Distribution System 1A and 1B fora 15 minutes.D- No Change[-q Difference
[I] Deviation
: 1) Listed site specific voltage and equipment to ensure timely classification.
: 2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 44 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU5Initiating Condition:
UNUSUAL EVENTLoss of all ornsite or offsite communications capabilities Operating Mode Applicability:
Cold Shutdown, Refueling, DefuledExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)CU4Initiating Condition:
Loss of all onsite or offsite communication capabilities.
Operating Mode Applicability:
5,6, DEmergency Action Levels (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting theability to perform routine operations.
OR2. Loss of ALL Table C1 Offsite communication capability affecting theability to perform offsite notifications.
OR3. Loss of ALL Table C1 NRC communication capability affecting theability to perform NRC notifications.
Table C1 Communications Ca pabilitySystem Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X XE No Change 1 Difference 1 Deviation
: 1) Listed site specific communications methods to ensure timely classification Page 45 of 66 NEI 99-01 Rev 6 Proposed EAL ] Justification CA3Initiating Condition:
ALERTInability to maintain the plant in cold shutdown.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upondetermining that the applicable has been exceeded, or will likely beexceeded.
: 1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater thanthe duration specified in the following table.2. UNPLANNED RCS pressure increase greater than (site-specific pressurereading).
(This EAL does not apply during water-solid plant conditions.
[PWR])CA5Initiating Condition:
Inability to maintain plant in cold shutdown.
Operating Mode Applicability:
5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. UNPLANNED rise in RCS temperature
> 2000F due to loss of decayheat removal for > Table C2 duration.
OR2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal.
(This EAL does not apply duringwater- solid plant conditions.)
1:1 No ChangeEl Difference
[--] Deviation
: 1) Listed site specific Technical Specification cold shutdown temperature limit toensure timely classification.
: 2) Listed site specific pressure reading to enhance timely classification.
: 3) Added wording relating the temp and press rise to a loss of decay heat removalcapability as per the developer notes for PWR'sTable: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up DurationStatusIntact (but notRCS Reduced Not Applicable 60 minutes*Inventory
[PWR])Not Intact (or at Established 20 minutes*reduced inventory
-[PWRJ) Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame andRCS temperature is being reduced, the EAL is not applicable.
Thht~ C2 RC~ Weat-,~m O.,rattnn Threchnids RCS Status Containment Closure Heat-up DurationStatusIntact Not Applicable 60 minutes*Not IntactEstablished 20 minutes*ORReducedInventory Not Established 0 minutesIf an RCS heat removal system is in operation within this timeframe and RCS temperature is being reduced, then EAL #1 is notapolicable.
Page 46 of 66 NPI 99-01 Rev 6 Proposed EAL Justification CU3Initiating Condition:
UNUSUAL EVENTUNPLANNED increase in RCS temperature.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 15 minutes time has been exceeded, or will likelybe exceeded,
: 1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vessel/RCS
[PWR] or RPV[BWRI) level indication for 15 minutes or longer.CU5Initiating Condition:
UNPLANNED rise in RCS temperature.
Operating Mode Applicability:
5,6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.
: 1. UNPLANNED rise in RCS temperature
> 200*F due to loss of decayheat removal.OR2. Loss of the following for > 15 minutes.* ALL RCS temperature indications AND* ALL RCS level indications D No Change E Difference FIDeviation
: 1) Listed site specific Technical Specification cold shutdown temperature limitto ensure timely classification.
: 2) Changed the word increase to rise in the initiating condition to be consistent with operations language and training.
Page 47 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification CG1Initiating Condition:
GENERAL EMERGENCY Loss of (reactor vessel/RCS IPWR] or RPV [BWRI) inventory affecting fuel cladintegrity with containment challenged.
Operating Mode Applicability:
Cold Shutdown.
Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 30 minutes time has been exceeded, or will likelybe exceeded.
: 1. a. (Reactor vessel/RCS
[PWRJ or RPV [BWRJ) vessel level less than (site-specific level) for 30 minutes or longer.ANDb. ANY indication from the Containment Challenge Table2. a.. (Reactor vessel/RCS
[PWR] or RPV [BWR]) vessel level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:
* (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication
[PWRJ* UNPLANNED increase in (site-specific sump and/or tank levels) ofsufficient magnitude to indicate core uncovery* (Other site-specific indications)
ANDc. ANY indication from the Containment Challenge Table).CG6Initiating Condition:
Loss of reactor vessel / RCS inventory affecting fuel clad integrity withcontainment challenged.
Operating Mode Applicability:
5,6H No Change E Difference 1 Deviation
: 1) EAL 1 a not included as per guidance in developer notes since top of activefuel is below level indication lowest value.2) Listed site specific radiation monitors to ensure timely classification
: 3) Listed site specific sumps and tanks to ensure timely classification
: 4) Listed Explosive mixture in the Containment Challenge Table to ensuretimely classification
: 5) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelyexceeded.
: 1. Reactor Vessel / RCS level unknown for >30 minutes.AND2. Core uncovery is indicated by ANY of the following:
* Table C3 indications of a sufficient magnitude to indicate coreuncoveryOR* Erratic Source Range Neutron Monitor indication.
OR* Radiation Monitor RM-G-6 or RM-G-7 reading > 3 R/hr.AND3. ANY Containment Challenge Indication (Table C4)beTable C3 Indications of RCS Leakage* UNPLANNED Reactor Building Sump level rise** UNPLANNED Auxiliary Bldg Sump level rise'* UNPLANNED BWST level rise'* UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss.Rise in level is attributed to a loss of reactor vessel/RCS inventory.
Table: Containment Challenge Table" CONTAINMENT CLOSURE not established*
* (Explosive mixture) exists inside containment
* UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWRI'if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.
Table C4 Containment Challenge Indications
" Hydrogen Concentration in Containment
> 4%* UNPLANNED rise in containment pressure" CONTAINMENT CLOSURE not established'
'if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to aGeneral Emergency is not required.
Page 48 of 66 NEI 99-01 Rev 6 1 Proposed EAL ] Justification CS1Initiating Condition:
SITE AREA EMERGENCY Loss of (reactor vesselIRCS
[PWR] or RPV [BWR]) inventory affecting coredecay heat removal capability.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 30 minutes time has been exceeded, or will likelybe exceeded.
: 1. a. CONTAINMENT CLOSURE not established.
ANDb. (Reactor vessel/RCS
[PWR) or RPV [BWR]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.
ANDb. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:
* (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication
[PWR]* UNPLANNED increase in (site-specific sump and/or tanklevels) of sufficient magnitude to indicate core uncovery* (Other site-specific indications)
CS6Initiating Condition:
Loss of reactor vessel / RCS inventory affecting core decay heat removalcapabilities.
Operating Mode Applicability:
5,6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.
: 1. Reactor vessel level unknown for >30 minutes.AND2. Core uncovery is indicated by any of the following:
* Table C3 indications of a sufficient magnitude to indicate coreuncoveryOR* Erratic Source Range Neutron Monitor indication.
OR* Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED Reactor Building Sump level rise** UNPLANNED Ausliary Bldg. Sump level rise'* UNPLANNED BWST level rise'* UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss'Rise in level is attributed to a loss of reactor vesselIRCS inventory.
[ No Change E Difference 1 Deviation
: 1) EAL 1 not included as per guidance in developer notes since 6" belowbottom ID of RCS loop is below level indication lowest value.2) EAL 2 not included as per guidance in developer notes since top of activefuel is below level indication lowest value,.3) Listed site specific radiation monitors to ensure timely classification
: 4) Listed site specific sumps and tanks to ensure timely classification
: 5) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 49 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationInitiating Condition:
ALERTLoss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 15 minutes time has been exceeded, or will likelybe exceeded.
: 1. Loss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory asindicated by level less than (site-specific level).2. a. (Reactor vessel/RCS
[PWRI or RPV [BWR]) level cannot bemonitored for 15 minutes or longerANDb. UNPLANNED increase in (site-specific sump and/or tank) levels dueto a loss of (reactor vessel/RCS
[PWR] or RPV [BWRI) inventory.
CABInitiating Condition:
Loss of reactor vessel / RCS inventory Operating Mode Applicability:
5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.
: 1. Loss of Reactor Vessel / RCS inventory as indicated by RCS level< 0 inches on Draindown Level indicator.
OR2. a. Reactor vessel / RCS level unknown for > 15 minutes.ANDb. Loss of reactor vessel / RCS inventory per Table C3 indications.
Table C3 Indications of RCS Leakage* UNPLANNED Reactor Building Sump level rise** UNPLANNED AuJliary Bldg. Sump level rise*UNPLANNED BWST level rise** UNPLANNED RCDT level rise'* UNPLANNED rise in RCS makeup* Observation of leakage or inventory lossRise in level is attributed to a loss of reactor vessel/RCS inventory.
D No Change I Difference L-- Deviation
: 1) Listed site specific levels to ensure timely classification.
: 2) Listed site specific sumps and tanks to ensure timely classification.
: 3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 50 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Cu1Initiating Condition:
UNUSUAL EVENTUNPLANNED loss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory for15 minutes or longer.Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.
: 1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS
[PWR] or RPV [BWR]) level less than a required lower limit for 15minutes or longer.2. a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot bemonitored.
ANDb. UNPLANNED increase in (site-specific sump and/or tank) levels.CU6Initiating Condition:
UNPLANNED loss of reactor vessel / RCS inventory for 15 minutes or longer.Operating Mode Applicability:
5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. UNPLANNED loss of reactor coolant results in the inability to restoreand maintain reactor vessel / RCS level to> procedurally established lower limit for >_15 minutes.OR2. a. Reactor vessel / RCS level unknown.ANDb. Loss of reactor vessel / RCS inventory per Table C3 indications.
El No Change I Difference FIDeviation
: 1) Described "a required lower limit" as a procedurally established lower limit,and listed site specific sumps and tanks to ensure timely classification.
: 2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table C3 Indications of RCS Leakage* UNPLANNED Reactor Building Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise"* UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakaoe or inventory loss*Rise in level is attrbuted to a loss of reactor vessel/RCS inventory.
Page 51 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG1HG1Initiating Condition:
GENERAL EMERGENCY HOSTILE ACTION resulting in loss of physical control of the facility.
Operating Mode Applicability:
AJlExample Emergency Action Levels:1. a. A HOSTILE ACTION is occurring or has occurred within thePROTECTED AREA as reported by the (site-specific security shiftsupervision).
ANDb. EITHER of the following:
: 1. ANY of the following safety functions cannot be controlled ormaintained.
Reactivity controlCore cooling [PWR] I RPV water level [BWRJ* RCS heat removalOR2. Damage to spent fuel has occurred or is IMMINENTInitiating Condition:
HOSTILE ACTION resulting in loss of physical control of the facility.
Operating Mode Applicability:
1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.
ORb. Damage to spent fuel has occurred or is IMMINENTD-- No Change F Difference Deviation
: 1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for atimely classification.
Table H1 Safety Functions
" Reactivity Control(ability to shut down the reactor and keep it shutdown)
" Core Cooling (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)Page 52 of 66 0NEI 99-01 Rev 6 Proposed EAL I Justification HS1HSIInitiating Condition:
SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.Operating Mode Applicability:
Initiating Condition:
HOSTILE ACTION within the Protected Area.Operating Mode Applicability:
E No Change FIDifference
[- Deviation
: 1) List site security shift supervision as Security Force.AllExample Emergency Action Levels:A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the (site-security shift supervision).
1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Page 53 of 66 NEI 99-01 Rev 6 J Proposed EAL Justification HA1Initiating Condition:
ALERTHOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attackthreat within 30 minutes.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2)1 A HOSTILE ACTION is occurring or has occurred within the OWNERCONTROLLED AREA as reported by the (site-specific security shiftsupervision).
: 2. A validated notification from NRC of an aircraft attack threat within 30minutes of the site.HA1Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airbome attackthreat within 30 minutes.Operating Mode Applicability:
1,2, 3,4,5, 6, DEmergency Action Levels (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutesfrom the site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring orhas occurred within the OWNER CONTROLED AREA.F-x No Change FIDifference F Deviation 1)Lisl site security shift supervision as Security Force.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:
UNUSUAL EVENTConfirmed SECURITY CONDITION or threat.Operating Mode Applicability:
HUIAJIExample Emergency Action Levels: (1 or 2 or 3)1. A SECURITY CONDITION that does not involve a HOSTILE ACTION asreported by the (site-specific security shift supervision).
: 2. Notification of a credible security threat directed at the site.3. A validated notification from the NRC providing information of an aircraftthreat.HU1Initiating Condition:
Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:
1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.
OR2. A validated notification from the NRC providing information of an aircraftthreat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.F No Change -IDifference LI1 Deviation
: 1) List site security shift supervision as Security Force.2) Further described credible security threat through listing a site specificprocedure.
Page 55 of 66 NEI 99-01 Rev 6 [Proposed EAL [Justification HS6Initiating Condition:
SITE AREA EMERGENCY Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 and 2)Note: The Emergency Director should declure the event promptly upon determining that (site-specific number of minutes) has been exceeded, or will likely beexceeded.
: 1. An event has resulted in plant control being transferred from the ControlRoom to (site-specific remote shutdown panels and local control stations).
: 2. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).
Reactivity control" Core cooling [PWRJ I RPV water level [BWR]RCS heat removalHS2Initiating Condition:
Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:
1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
: 1. A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per OP-TM-EOP-020, Cooldown from Outsidethe Control Room.AND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table HI Safety Functions
* Reactivity Control(ability to shut down the reactor and keep it shutdown)
* Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)FD No Change M Difference 1 Deviation
: 1) EAL uses the site specific Control Room evacuation procedures toeffectively list all of the alternate locations, panels, and stations requested bythe developer notes. This would be the procedures the Control Room wouldenter should such an event occur, this allows for greater clarity as to whenthis EAL would apply than if each panel and station used in alternate shutdown were to be listed,2) Added descriptors to better explain each safety function and allow for atimely classification.
: 3) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlroom still manned, due to testing or equipment failure.Page 56 of 66 NEt 99-01 Rev 6 1 Proposed EAL IJustification HA6HA2Initiating Condition:
ALERTInitiating Condition:
D No Change[F Difference
--] Deviation Control Room evacuation resulting in transfer of plant control to alternate locations.
I Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
AllExample Emergency Action Levels:An event has resulted in plant control being transferred from the Control Room to(site-specific remote shutdown panels and local control stations).
Operating Mode Applicability:
1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):A Control Room evacuation has resulted in plant control being transferred fromthe Control Room to alternate locations per OP-TM-EOP-020, Cooldown fromOutside the Control Room.1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would enter should such anevent occur, this allows for greater clarity as to when this EAL would apply than ifeach panel and station used in alternate shutdown were to be listed,2) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlroom still manned, due to testing or equipment failure.Page 57 of 66 NEI 99-01 Rev 6 j Proposed EAL Justification HU4HU3Initiating Condition:
UNUSUAL EVENTFIRE potentially degrading the level of safely of the plant.Operating Mode Applicability:
Initiating Condition:
FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:
1,2, 3,4, 5, 6, DLII No Change [-] Difference
[] Deviation
: 1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEMequipment to ensure timely classification.
AllExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Eventpromptly upon determining that the applicable time has beenexceeded, or will likely be exceeded.
: 1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:
* Report from the field (i.e., visual observation)
* Receipt of multiple (more than 1) fire alarms or indications
* Field verification of a single fire alarmANDb. The FIRE is located within ANY of the following plant rooms or areas:(site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).ANDb. The FIRE is located within ANY of the following plant rooms or areas:(site-specific list of plant rooms or areas)ANDc. The existence of a FIRE is not verified within 30-minutes of alarm receipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plantProtected Areal PROTECTED AREA not extinguished within 60-minutes ofthe initial report, alarm or indication.
: 4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plantProtected Areal PROTECTED AREA that requires firefighting support by anoffsite fire response agency to extinguish.
Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. a. A FIRE in any Table H2 area is not extinguished in <15-minutes of ANYof the following FIRE detection indications:
* Report from the field (i.e., visual observation)
* Receipt of multiple (more than 1) fire alarms or indications
* Field verification of a single fire alarmOR2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no otherindications of a FIRE).ANDb. The existence of a FIRE is not verified in <30-minutes of alarm receipt.OR3. A FIRE within the plant PROTECTED AREA not extinguished in <60-minutes of the initial report, alarm or indication.
OR4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Table H2 Vital Areas* Reactor Building* Intake Building* Intermediate Building* Control Tower* Auxiliary and Fuel Handling Buildings
* 1A and 1 B Diesel Generator Buildings
* BWST* CSTPage 58 of 66 0NEI 99-01 Rev 6 [Proposed EAL ] Justification Initiating Condition:
UNUSUAL EVENTSeismic event greater than OBE levels.Operating Mode Applicability:
HU2AllExample Emergency Action Levels:Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:a. (site-specific indication that a seismic event met or exceeded OBE limits)HU4Initiating Condition:
Seismic event greater than OBE levels.Operating Mode Applicability:
1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by seismicAlarms PRF-1-3 Operating Basis earthquake and PRF-1-2 Threshold SeismicCondition.No Change 1 Difference FIDeviation
: 1) Listed site specific indication to determining OBE limits have been met orexceeded to ensure timely classification.
Page 59 of 66 NEI W9-01 Rev 6 Proposed EAL [Justification HA5Initiating Condition:
ALERTGaseous release impeding access to equipment necessary for normal plantoperations, cooldown or shutdown.
Operating Mode Applicability:
AilExample Emergency Action Levels:Note: If the equipment in the listed room or area was already inoperable, or outof service, before the event occurred, then no emergency classification iswarranted.
: 1. a. Release of a toxic, corrosive, asphyxiant or flammable gas into anyof the following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)
ANDb. Entry into the room or area is prohibited or impeded.HA5Initiating Condition:
Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note: If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification iswarranted.
I. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.No Change FIDifference FIDeviation
: 1) Listed plant specific rooms and areas with entry related mode applicability toensure timely classification.
Table H3Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 4, 5, and 6Intermediate Building*
Modes 4, 5, and 6Auxiliary Building*
Modes 4, 5, and 6Fuel Handling Building*
Modes 4, 5, and 6*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededPage 60 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:
UNUSUAL EVENTHazardous EventOperating Mode Applicability:
HU3AtlExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: EAL #3 does not apply to routine traffic impediments such as fog, snow.ice, or vehicle breakdowns or accidents.
I. A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require manualor automatic electrical isolation of a SAFETY SYSTEM component neededfor the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due toan offsite event involving hazardous materials (e.g., an offsite chemicalspill or toxic gas release).
: 4. A hazardous event that results in on-site conditions sufficient to prohibitthe plant staff from accessing the site via personal vehicles.
: 5. (Site-specific list of natural or technological hazard events)HU6Initiating Condition:
Hazardous EventOperating Mode Applicability:
1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice,or vehicle breakdowns or accidents.
: 1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to anoffsite event involving hazardous materials (e.g., an offsite chemical spill ortoxic gas release).
OR4. A hazardous event that results in on-site conditions sufficient to prohibit theplant staff from accessing the site via personal vehicles.
OR5. Abnormal river water level at the intake Pump and Screen House, as indicated by EITHER:a. > 300 ft. el. (high level)ORb. < 274 ft. el. (low level)F No Change F Difference FIDeviation
: 1) Included river water level as part of the site-specific list of natural ortechnological hazard events. The EAL values selected are the current ApprovedUE EAL values.2) Changed the word "needed" to "required by Technical Specifications" in the EALto be consistent with terminology used by operators and minimize confusion.
Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL [Justification HG8HG7Initiating Condition:
GENERAL EMERGENCY Initiating Condition:
x-1 No Change FIDifference FIDeviation Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.
Operating Mode Applicability:
AllExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control ofthe facility.
Releases can be reasonably expected to exceed EPA Protective ActionGuideline exposure levels off-site for more than the immediate site area.Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.
Operating Mode Applicability:
1,2, 3,4.5, 6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control ofthe facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..Page 62 of 66 SNEI 99-01 Rev 6 1 Proposed EAL Justification HS8HS7Initiating Condition:
SITE AREA EMERGENCY Initiating Condition:
M No Change. FIDifference 1-- Deviation Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency.
Operating Mode Applicability:
AJIExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely majorfailures of plant functions needed for protection of the public or HOSTILE ACTIONthat results in intentional damage or malicious acts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are notexpected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency.
Operating Mode Applicability:
1,2,3,4,5,6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely majorfailures of plant functions needed for protection of the public or HOSTILE ACTIONthat results in intentional damage or malicious acts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are notexpected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.
Page 63 of 66 NEI 99-01 Rev 6 ] Proposed EAL j Justification HA6Initiating Condition:
ALERTInitiating Condition:
HA7H No Change U Difference 1 Deviation Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an Alert.Operating Mode Applicability:
AlUExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to siteequipment because of HOSTILE ACTION. Any releases are expected to belimited to small fractions of the EPA Protective Action Guideline exposure levels.Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an Alert.Operating Mode Applicability:
1, 2, 3, 4, 5, 6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to siteequipment because of HOSTILE ACTION. Any releases are expected to belimited to small fractions of the EPA Protective Action Guideline exposure levels.Page 64 of 66 NEI 99-01 Rev 6 Proposed EAL [Justification HU7Initiating Condition:
UNUSUAL EVENTOther conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:
AlIExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated.
No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systemsoccurs.HU7Initiating Condition:
Other conditions existing which in thejudgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:
1,2,3,4,5,6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated.
No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systemsoccurs.W-1 No Change 1 Difference FIDeviation Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL Justification E-HU1mInitiating Condition:
UNUSUAL EVENT [-j No Change [ Difference
[j Deviation Damage to a loaded cask CONFINEMENT BOUNDARY.
TMI Station does not have an ISFSI,Operating Mode Applicability:
AllExample Emergency Action Levels:Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specifictechnical specification allowable radiation level) on the surface of the spent fuelcask.Page 66 of 66 Tkrgm U11m lalonA Qfatinn AnndmvPI:Yslnn h,:l"AarTkra~ u;ia I@IavmI ~*a*ij~mi Auinww Fv~Ir~n FJm.rI~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARG1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRfem TEDEor 5000 mRfem thyroid CDE.Operating Mode Applicability:
1,2,3, 4,5,6, DEmergency Action Level (EAL):Notes:e The Emergency Director should declare the Gonoral Emergency event promptly upondetermining that the applicable time has been exceeded, or will likely be exceeded.
e If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established.
If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.
* The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.
(1) Reading on ANY Of the folWIG ng radiation monitor-s greater than the reading shownfor 15 minutes Or longer:(cito SPoific moniRtor list and threshold v:alues)1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment Using actual meteorology indicates doses at or beyond (site-.... ;f*c doco r..ec.. Point) the site boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidORMonth 20XXTMI 3-1EP-AA-1009 (Revision XX) hroa Uila hainnel qtntinn AnnoyI=ynlnn N.nlpar1 II I Mii I isand Vtsat I AnnII vl IIE inn NucleaIrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS r-:iJ -ReluS~ve rA,.ArU4A r.,%iy8+-
a.9 Q teFbeetts
/%1 .... I * ...'-- --II .... J ...... JL__ __---__ -aL_ _ aa r'/'#', l ,L _--A A .JA -- --!A .... L----Closed windew dese FaTes WeffieF MaR JWWU FAPVRF eXPeGleO W GGRIIRUe f9fP60rMAtesn OrIrr(jnr I I ia I II ; I Pfor one hour Of inhalation.
: 3. Field survey results at or beyond the site boundarv indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate
> 5000 mRem CDE Thyroid for60 minutes of inhalation.
Table R1 Effluent Monitor Thresholds Effluent Monitor General Emergency RM-G-25 (Cond Offqas) 9.53 E+06 mR/hrRM-A-8GH (Station Vent) 3.09 E+05 cpmRM-G-24 (RB Purge) 5.55 E+05 mR/hrRM-A-14 (ESF Vent) 6.66 E+02 uCi/ccBasis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases.
Releases of this magnitude willrequire implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.
The TEDE dose is set at the EPA PAG of 1000 mR-em while the 5000 mR-em thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.larssjification based on effluent monitor readings assumos that a release path to thenVironm~ent is, established.
if the effluent flow past an effluont moniorF 06 known to havMonth 20XXTMI 3-2EP-AA-1 009 (Revision XX) hrom Uila lainnei Qtatinn AnnovFYAInn Thr~Mu. chani ~tatin Anny Fvinn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS stopped due to actioea to- ioel-ate the releaso path, then the offluent moni;tor reading is- nolongor valid for clascification purpococ.
Basis Reference(s):
: 1. NE 199-01 Rev 6, AG12. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island3. EP-AA-1 12-500 Emergency Environmental Monitoring
: 4. FSAR Section 11.4 Radiation Monitoring System5. EP-AA-1 10-200 Dose Assessment
: 6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XXTMI 3-3EP-AA-1009 (Revision XX)
Three Mile tIslnd Station Annex E~xelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARSlInitiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mR-em TEDEor 500 mRfem thyroid CDE.Operating Mode Applicability:
1,2,3,4,5,6, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the Site Aoa Emergency event promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.
e If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established.
If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.
e The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.
(1) Reading on ANY Of the folloWing radiation mon.itors greater than the reading shownfor 15 minute O or lenger:
moRnitor list and threshold values)(2) Doeo assessment using acatual mneteorology indicates, doses greater than 100nre~m TEDES or 50 mrom thyroid CDE at Or boyen d (cite-specific dose recepto(3) Field cur.'ey rocults indicate EITHER of the following at Or beyond (cite specificdoe receptor pGOit):" Closed window dose rates greater-than 100 mR/hr expected to continue for 60 m~inutes" Analyses of field sun~ey samples indieate thyfeid CDE greater-than 500 maemn for: onehour- of inhalationi.
: 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.ORMonth 20XXTMI 3-4EP-AA-1009 (Revision XX)
Throp RAila 1-cland Atntinn AnnpvN.nlpnrThre Mil l~IanrI~tetnn AnexExelon Nucl~earTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
: 2. Dose assessment usina actual meteoroloav indicates doses at or bevond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundarv indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for > 60 minutes.ORAnalyses of field survey samples indicate
> 500 mRem CDE Thyroid for 60minutes of inhalation.
Table R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency RM-G-25 (Cond Offgas) 9.53 E+05 mR/hrRM-A-8GH (Station Vent) 3.09 E+04 cpmRM-G-24 (RB Purge) 5.55 E+04 mR/hrRM-A-14 (ESF Vent) 6.66 E+01 uCi/ccBasis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases.
Releases of this magnitude areassociated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.
The TEDE dose is set at 10% of the EPA PAG of 1000 mR-em while the 500 mR-emthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.%*~!1!k!
L....J -- .EtI....L
.!J.-A AI A J --I-lG-asiairatcaion hased on crnuten Imon-Tior r*SoAuinu assumos ;Rna
* a r eicase eatrn tov..Month 20XXTMI 3-5EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS the environmcnt is octablished.
if the cfflucnt flow past an effluent.mntri known tohave stopped due to actions to ilthe thoreease path, then the effluent monGitor readgis no longer valid for claesificatio pupoosEscalation of the emergency classification level would be via IC RAG1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AS12. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island3. EP-AA-1 12-500 Emergency Environmental Monitoring
: 4. FSAR Section 11.4 Radiation Monitoring System5. EP-AA-1 10-200 Dose Assessment
: 6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XXTMI 3-6EP-AA-1 009 (Revision XX)
ExAIon NuelAarThriat Mia Ihqanrd Station Annex ExeInn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA1Initiating Condition:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRiemTEDE or 50 mRfem thyroid CDE.Operating Mode Applicability:
1,2,3, 4,5,6, DEmergency Action Level (EAL):Notes:9 The Emergency Director should declare the Alet-event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established.
If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.
e The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.
for 15 m"inutes or longer:(site6 pecific moRntor list and threshold v.'alues)
(2) Dose assessment using actual metoorolOg';
indicates dosees greater than 10 mrcmTEDE or 50 mromn thyroid CDE at or beYOnd (site spocific dose recee9tor pEGinfl.l i *(3) Analysis of a liquid effluent sample indicates a concentration Or release rate thatwould result in dosces greater than 10 mrom~ TEDE Or 50 mromn thyroid CDE atobeyond (site-specific dose receptor point) for ono hour Of exposure-.
(4) Field su...ey results indicate EITHE.R o.f t.he following at or beyond (sit, .pecificdose receptor pint):* Closed window dose rates ereater-than L0 fo'hr exoeetd to eantinue fer 60 fmutes orlenger-.a &#xb6; Jl" * " ] a~~~ a-*"~ a~ '-*-U*" v..%= a*'" ar'~~ aafia + mrr at-Pr fa"= AW 41MJ4 LAAA. ARPvhour of inhalation.
j b- -Month 20XXTMI 3-7EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
: 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate
> 50 mRem CDEThyroid for 60 minutes of inhalation.
Table R1 Effluent Monitor Thresholds Effluent Monitor AlertRM-G-25 (Cond Offqas) 9.53 E+04 mR/hrRM-A-8GH (Station Vent) 3.09 E+03 cpmRM-G-24 (RB Purge) 5.55 E+03 mR/hrRM-A-14 (ESF Vent) 6.66 E+00 uCVccMonth 20XXTMI 3-8EP-AA-1 009 (Revision XX)
Thrgna MiIA lalanfi Qtafirnn AnnovIFwalnn N, AalarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual offsite doses greater than or equal to 1% of the EPA Protective Action Guides(PAGs). It includes both monitored and un-monitored releases.
Releases of thismagnitude represent an actual or potential substantial degradation of the level of safety ofthe plant as indicated by a radiological release that significantly exceeds regulatory limits(e.g., a significant uncontrolled release).
Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.
The TEDE dose is set at 1% of the EPA PAG of 1000 mRfem while the 50 mR-em thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classiffication based on effluent monefitonr re-adfings acsumos that a roleaso path tothe enViroAnment is established.
If tho effluent flow-past.
an Aeffiluent moenitor is known tohave stopped duo to acti;ons to isolato the release path, then the offluePnt mnonitor reRaing;s no Ilnger valid forclasif;cation purpoe s.7Escalation of the emergency classification level would be via IC RAS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AA12. OP 1101-2.1 Radiation Monitoring System Setpoints
: 3. FSAR Section 11.4 Radiation Monitoring System4. OP-TM-MAP-CO101, Radiation Level HI5. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island6. EP-EAL-0616, Revision 0, Three Mile Island Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values7. EP-EAL-0622, Revision 0, Three Mile Island Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values for Waste Gas Decay TanksMonth 20XXTMI 3-9EP-AA-1 009 (Revision XX)
Tkrg%,A%
Uilg% lalonri Qfation AnnavI:valrnn Hnn-lmarTkr~ MiI~ I.IanrI Qt~tirui Ann~v Fv.Inn Muu~I.~ar B B 1 *W*BB *5* 5 tt*WU .rB. B. j,~ * * -,*TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARUMInitiating Condition:
Release of gaseous or liquid radioactivity greater than 2 times the ODCM (kste-speelfiG efflu.nt
.eloase controlling document) limits for 60 minutes or longer.Operating Mode Applicability:
1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the Unusual Event event promptly upondetermining that 60-minutesthe applicable time has been exceeded, or will likely beexceeded.
" If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established.
If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.
(1) Reading on ANY effluent radiation monitor than 22 timnes t-he- (site specificeffluent release oRntrolling d.,umont).
Imits for 60 minutes Or Ilnger(cite-specific monitor list and threshold values corresponding to 2 times theControlling I-Mits(2) Reading on ANY effluent radiation monitor greater than 2 times the alar m setpestablished by a current radioactiveity discharige permit for 60 minutes or longer.(3) Sample analysis for a gaseous Or liquid release indicateS
-a concentration orrelease rate greater than 2 times th (site-specfific effluent release controllig documnent) limnits for 60 minutes Or longer.1. Reading on any of the following effluent monitors
> 2 times alarm setpointestablished by a current radioactive release discharge Permit for 2:60 minutes.i. RM-L-6, Radwaste Discharge ii. RM-L-1 2, IWTS / IWFS Discharge iii. RM-A-7, Waste Gas Decay Tank Discharge iv. Discharge Permit specified monitorOR2. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60 minutes.ORMonth 20XXTMI 3-10EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS
: 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual EventRM-G-25 (Cond Offoas) 1.09 E+03 mR/hrRM-A-8GH (Station Vent) 7.03 E+01 cpmRM-G-24 (RB Purge) 6.34 E+01 mR/hrRM-A-14 (ESE Vent) 7.60 E-02 uCi/ccBasis:This IC addresses a potential decrease in the level of safety of the plant as indicated by alow-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release).
It includes any gaseous or liquidradiological
: release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.
Nuclear power plants incorporate design features intended to control the release ofradioactive effluents to the environment.
: Further, there are administrative controlsestablished to prevent unintentional
: releases, and to control and monitor intentional releases.
The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.
Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.
C-larssific-attion based on effluent moenitor ro-ad-ings assumes that a rclease pathtthe enVrOFnment ir, established.
if the effluent flow p'tanefluent moni~tor is knownthave Mtopped duo to ac-tions to islthe- Ih 'eosah, then the effluent monitor road-ingsc no longer valid for clIiiaioGupss Releases should not be prorated or averaged.
For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.EAL #1 Basis:EAL-#2--
This EAL addresses radioactivity releases that cause effluent radiation monitorreadings to exceed 2 times the limit established by a radioactivity discharge permit. ThisEAL will typically be associated with planned batch releases from non-continuous releaseoathwavs (e.g.. radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges.
If adischarge is performed using a different flowpath or effluent monitor other than thoseMonth 20XXTMI 3-11EP-AA-1009 (Revision XX) hrgga Uffis lalzanA Qtatinn Anniovi=Yplnn NiJnlpnrThr~ MIle Iclenri ~t~atinn Annev Fv~Inn Niir~Ic&~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS listed (e.g., a portable or temporary effluent monitor),
then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 Basis:EAL-#1---This EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous erI-iquid-effluent pathways.
EAL #3 Basis:EAL--#3 -This EAL addresses uncontrolled gaseous or liquid releases that are detectedby sample analyses or environmental
: surveys, particularly on unmonitored pathways(e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river watersystems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AU12. OP 1101-2.1 Radiation Monitoring System Setpoints
: 3. FSAR Section 11.4 Radiation Monitoring System4. Offsite Dose Calculation (ODCM)5. OP-TM-MAP-CO101, Radiation Level HI6. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile IslandMonth 20XXTMI 3-12EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon NuclanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA2Initiating Condition:
Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:
1,2,3, 4,5,6, DEmergency Action Level (EAL):(1) Uncovor';
Of irradiatcd fuel in the REFUELING P.ATHWIA.IY.
: 2. Damage to irradiaced fuel resulting in a release of radioacivity from the fuel asindicated by ANY of R2 Radiation Monitorr i(sito Spocific listiRg of radiation
: monitors, and tho associated
: roadings, s Rtpoints and/RB alarms)(3) LIwonng of spent fuel pool level to (sitee tu pific Level 2 value). [tqh whv3ichNOtefe1 -Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R2 Radiation Monitor reading >1000 mRemlhrTable R2____________
Radiation Monitors_____
RMS Area Monitored ModeRM-G-9 FHB3 Bridge Rad Monitor ALLRM-G-6 RB Auxiliary Bridge Rad Monitor 5.6RM-G-7 RB Main Bridge Rad Monitor 5.6Basis:REFUELING PATHWAY:
all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.Month 20XXTMI 3-13EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS IMMINENT:
The traiectory of events or conditions is such that an EAL will be met within arelatively short period of time regardless of mitigation or corrective actions.This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly_.,
or a -nifclant low..ring of ,.,atar le. , within the ,pent fuel pool (SeeDeveloper.
,te,). These events present radiological safety challenges to plantpersonnel and are precursors to a release of radioactivity to the environment.
As such,they represent an actual or potential substantial degradation of the level of safety of theplant.This IC applies to irradi-atteed fueel that is licensod for dr; storage up to the point tatho loaded storage cask is soaled. Once sealed, damage to a leaded cask causing lescof the CONFINEMENT B1OUNDARY is, classified in accrdance with CG EHLHJl...c.alation o tho oM dd bo hb.c.d on pithor .e.ogniio.n
.o.a.... A or C .C. .EAL #1 Basis:E-AL-41This EAL escalates from RAU2 in that the loss of level, in the affected portion of theREFUELING
: PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visualobservation (e.g., reports from personnel or camera images),
as well as significant changes in water and radiation levels, or other plant parameters.
Computational aidsmay also be used (e.g., a boil-off curve). Classification of an event using this EAL shouldbe based on the totality of available indications, reports and observations.
While an area radiation monitor could detect aA iieaeerise in a dose rate due to alowering of water level in some portion of the REFUELING
: PATHWAY, the reading maynot be a reliable indication of whether or not the fuel is actually uncovered.
To the degreepossible, readings should be considered in combination with other available indications ofinventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 Basis:EAL-#2This EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly.
A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of apotential fuel damaging event (e.g., a fuel handling accident).
Month 20XXTMI 3-14EP-AA-1009 (Revision XX)
I::xelon Nucl@arThrop Mile~ Island Staition Annex Exelon NuceianrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency would be based on either Recognition Category R A-or CEA #3Spent fuel pool water level at this value ir, within the low,,er And of the level rangeneccary to prevent significant dose conseguoncos from direct gamma radiation toperconnel performing eperations in the V.icinity Of the cpent fuel peel. This conditoreflects a significant loss Of spcnt fuol pool water inventor; and thus it. is alsoRa a precursor two t .. *f tt V 7 w 5m ra ,- 7 c5 q5
* W !C-- ---s ,^ -----t- ,Esclatonof the emorgnonc Gla6ification leveXl wo.AUld be via I~s A8i Or A82 f(se ASD v.,l,.rr Aot,).Basis Reference(s):
: 1. NEI 99-01 Rev 6, AA22. Operating Procedure OP-TM-MAP-C0105 RCS Draindown LVL HI/LO3. OP-TM-MAP-CO101, Radiation Level HI4. UFSAR, Section 14.2.2.1
-"Fuel Handling Accident" 5 Technical Specification 3.8.11 (Reactor Cavity Level)6. Operating Procedure OP 1101-2.1 Radiation Monitoring System Setpoints Month 20XXTMI 3-15EP-AA-1009 (Revision XX)
N.cIAarThro* wisw kthand Stamtion Annexv EvAnn TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARU2Initiating Condition:
UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:
1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):/i4 x I IKlDI AKllII r-wl l A in=,nI ;r% +km OCh C lII I l In-_ DAT1IfAIAV
\'/k.~. AKN -; 6"-n n~n.,.,.i i&#xfd;i i i F iz a-- ...........
-(Site G~ecific loeve'l indicatiens).
AkINI.A.ND--1 1- -A as%* 9 1-~r.I S *I 1 ~ U U* III L4* L4 S L4U~tI~5 U
* Y~U ~A US SASSA~ flSU U 5 ti 5u=fowfeiwn Faife lnenfter
*(sitospocif ic list of aroa radi-ation monitor)1. a. UNPLANNED water level drop in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R2.Table R2Radiation MonitorsRMS Area Monitored ModeRM-G-9 FHB Bridge Rad Monitor ALLRM-G-6 RB Auxiliary Bridge Rad Monitor 5,6RM-G-7 RB Main Bridge Rad Monitor 5, 6Basis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.Month 20XXTMI 3-16EP-AA-1009 (Revision XX)
NuclearThree Mile Island Staition Annex Exelnn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS REFUELING PATHWAY:
all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a deGrease-loss in water level above irradiated fuel sufficient to causeelevated radiation levels. This condition could be a precursor to a more serious eventand is also indicative of a minor loss in the ability to control radiation levels within theplant. It is therefore a potential degradation in the level of safety of the plant.I A water level deGrease-loss will be primarily determined by indications from available levelinstrumentation.
Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) or fromany other temporarily installed monitoring instrumentation.
A significant drop in the waterlevel may also cause an inRGeaserise in the radiation levels of adjacent areas that can bedetected by monitors in those locations.
The effects of planned evolutions should be considered.
For example, a refueling bridgearea radiation monitor reading may iGFreaserise due to planned evolutions such as liftingof the reactor vessel head or movement of a fuel assembly.
Note that this EAL isapplicable only in cases where the elevated reading is due to an UNPLANNED loss ofwater level.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AU22. UFSAR, Section 14.2.2.1
-"Fuel Handling Accident"
: 3. OP-TM-MAP-CO105 RCS Draindown
: 4. OP 1202-12, Excessive Radiation Levels5. OP 1101-2.1 Radiation Monitoring System Setpoints
: 6. Technical Specification 3.8.11 (Reactor Cavity Level)Month 20XXTMI 3-17EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA3Initiating Condition:
Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
1,2,3,4,5,6, DEmergency Action Level (EAL):Note: If the equipment in the listed-room or area listed in Table R4 was alreadyinoperable, or out of service, before the event occurred, then no emergency classification is warranted (1) Dooe Fate gr.ator than, 15 in ANY of the ar.as. :* Control Roomw9 (other- site speeitie afeas~r-eefn) fO~t An~ UKINIDIAWNIRfl Aumth mra.u, Or, *n mlotrr' levels that anrihibet OF irneedc aGcrns ta ~ S I.~ *11I 4a II a..a.r.n rI y. .h* main a. am flmaa% as.I J IV T ViV 5i VI Vi IIVIt VI Ill KVVVVV tV__. -----J I--vvIEI I I R I iisitelsoeGG isi t or plant rooms orareas wutn enir: roiatoa moac avvilcaHl)lty l1. Dose rate QreateF than> 15 mR/hr in ANY of the areas contained in Table R3:Table R3Areas Requiring Continuous Occupancy
* Main Control Room* Central Alarm Station -(by survey)ORMonth 20XXTMI 3-18EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
: 2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to any of the following Table R4 plant rooms or areas:Table R4Areas with Entrv Related Mode Aplicability Area Entry Related ModeApplicability Reactor Building*
Modes 4, 5. and 6Intermediate Building*
Modes 4. 5. and 6Auxiliary Building*
Modes 4. 5, and 6Fuel Handling Bujildng*
Modes 4. 5. and 6*Areas required to establish shutdown coolingBasis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantprocedures--maintain normal plant .p..atin, Or to pcftm a normal plant cooldown andsh'Jtdo-n.
As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.
Table R4 is a list of plant rooms or areas with entry-related mode applicability that containequipment which reguire a manual/local action necessary to transition the plant fromnormal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling),
where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.
This Table does not includerooms or areas for which entry is reguired solely to perform actions of an administrative orrecord keeping nature (e.g., normal rounds or routine inspections).
Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and the elevatedradiation levels preclude the ability to place shutdown cooling in serviccat tho tome of theclevated radiation le:ecl. The emergency classification is not contingent upon whetherentry is actually necessary at the time of the increased radiation levels. Access should beconsidered as impeded if extraordinary measures are necessary to facilitate entry ofMonth 20XXTMI 3-19EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS personnel into the affected room/area (e.g., installing temporary shielding beyond thatrequired by procedures, requiring use of non-routine protective equipment, requesting anextension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the time ofthe elevated radiation levels).
For example, the plant is in Mode 1 when the radiation iP,-easerise occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room orarea (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections).
" The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category BA, Cor F ICs.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AA32. FSAR Section 5.01 Class I Structures, Components, and Systems3. OP-TM-MAP-CO101, Radiation Level HIMonth 20XXTMI 3-20EP-AA-1009 (Revision XX)
Throm Milo lalanrl Qtafinn AnnoyFyislnn NurnlparTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):ran a.l .n a a ran*n.. *k nn ia~v,* ^;*;* S,,l1, -I -~'-I....... * ..... r:~ mni 3~I~I IfOICTO~Tf3T rnc~o colan aciv~y .mio i oraTo ma ail k! !; ;+ of I A I -r k ; i Q ;f; +; n.....-j-- ------------..- ...--...Ct %7vrct W M OPWID CY ri V0 ri out F7%70 %7= 17 17-1. Letdown Monitor RM-L-1 alert alarm (high or low channel).
OR2. Sample analysis indicates that:a. Dose Equivalent 1-131 specific coolant activity
> 60.0 uCVgm.ORb. Dose Equivalent XE-133 specific coolant activity>
797.0 uCi/lm.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications.
This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel claddegradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of adegradation of fuel clad integrity.
An Unusual Event is only warranted when actual fuel clad damage is the cause of theelevated coolant sample activity (as determined by laboratory confirmation).
Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category BA ICs.Month 20XXTMI 3-21EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU32. Operating Procedure 1101-2.1 Radiation Monitoring System Setpoints
: 3. FSAR Section 11.4.4, Liquid Monitoring Subsystem
: 4. OP-TM-MAP-C0101, Radiation Level HI5. Technical Specifications 3.1.4, Reactor Coolant System ActivityMonth 20XXTMI 3-22EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FG1Initiating Condition:
Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.
At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-23EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FS1Initiating Condition:
Loss or Potential Loss of ANY two barriers.
Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.
At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-24EP-AA-1009 (Revision XX)
Thrao M~iId Wcandl Qtatinn AnnoyI=:talnn Nhlo irlrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FA1Initiating Condition:
ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.
At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier.
Unlike the Containment
: barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.
Note that the loss or potential loss ofContainment barrier in combination with loss or potential loss of either Fuel Cladding orRCS barrier results in declaration of a Site Area Emergency under EAL FS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-25EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC1Initiating Condition:
RCS or SG Tube LeakageOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSSA. RCSloactor v~eseol leveol less than (site spccific value).1. RCITS hot leg instruments indicate 0 inches after lowering trend.AND2. In-core thermocouples are unavailable.
AND3. ALL RCP's are secured.Basis:There is no Loss threshold associated with ROS or SG Tube Leakage.Potential Loss Threshold Basis:This reading indicates a reduction in reactor vessel water level sufficient to allow theonset of heat-induced cladding damage.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. FSAR 7.3.2.2.c.
10.d3. OP-TM-EOP-008, RCS Superheated
: 4. OP-TM-EOP-010, Emergency Procedure Rules Guides and GraphsMonth 20XXTMI 3-26EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC2Initiating Condition:
Inadequate Heat RemovalOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSSA. Core Exit Them~ecouplo readings greater than (site sepoific temper-ature value)1. Tcad > 1400&deg;FPotential LossA. Co re exit thorMOcouplo reading s greater than (site sepocfic temperature value).d k;!;#I~~t
.f n4%nv -4%San,%e
;~ A;lt*i A k~ (.4rn~. ^S- ------aIn .... .%"ry ry V rt r. mrtr" ""m "M -Mft- 11"U."U" V5 Ift "cpocific niain)2. > 25&deg;F Superheat OR3. HPI-PORV Cooling in effect--r--,# * ....Basis:Loss Threshold
#1 BasisL~es&-2-A ThisFeadmig-ilndicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.Potential Loss Threshold
#2 BasisPotential Loes 2.A.
temperatures within the core are sufficient to allow the onset ofheat-induced cladding damage.Potential Loss Threshold
#3 Basis L ,,os [2BThis condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier.
In accordance with EOPs, theremay be unusual accident conditions during which operators intentionally reduce theMonth 20XXTMI 3-27EP-AA-1009 (Revision XX)
NuclearThree Mile Island Station Annex Exellon NuclasrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.
Meeting this threshold results in a Site Area Emergency because this threshold isI identical to RCS Barrier RC2 Potential Loss threshold-2-A; both will be met. Thiscondition warrants a Site Area Emergency declaration because inadequate RCS heatI removal may result in fuel heat-up sufficient to damage the cladding and inireaseraise RCS pressure to the point where mass will be lost from the system.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. OS-24 Attachment D3. OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer4. OP-TM-EOP-008, RCS Superheated
: 5. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs6. OS-24, Conduct of Operations during Abnormal and Emergency EventsMonth 20XXTMI 3-28EP-AA-1009 (Revision XX)
Thrdam Uilm lainnel tatinn AnnoyI=Yplnn NnnlanrTkraa Mum IcImnrI ~tmtinn Ann.v Fv.Inn NuIr~IsrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC3Initiating Condition:
Containment Radiation
/ RCS ActivityOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSS1A. Containment radiation monitor roading grcatc. than (site epcific valuc)(RM-G-22 or RM-G-23) reading > 1.95E+03 R/hr.OR?8. (Sitoe-pocific indications that roactOr coolant activ.ity is groator than 300uGi'gm dose equivalent 1 131) Coolant activity as sampled > 300uCi/gm Dose Equivalent 1-131Basis:Loss Threshold
#1 BasisLess4-3AThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equals300jiCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greaterthan that expected for iodine spikes and corresponds to an approximate range of 2% to5% fuel clad damage. Since this condition indicates that a significant amount of fuelclad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCSBarrier RC3 Loss Tthreshold
&A-since it indicates a loss of both the Fuel Clad Barrierand the RCS Barrier.
Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.
Loss Threshold
#2 BasisThis threshold indicates that RCS radioactivity concentration is greater than 300 RCi/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete.
Nonetheless, asample-related threshold is included as a backup to other indications Month 20XXTMI 3-29EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION There is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity
/Containment Radiation.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-MAP-CO101, Radiation Level HI3. FSAR Section 11.4.4, Liquid Monitoring System Description
: 4. Calculation C3640-98-034, Prediction of the Response of RM-G-6 and 7 to FuelDamage5. Core Damage Assessment Methodology (CDAM)Month 20XXTMI 3-30EP-AA-1 009 (Revision XX) hrAmAm Uila lalonrl Qtafinn AnnovF:yalnn N"~lAarTkra~ Mum I@kanrl ~t~tinn Anninv Fvmlnn M.mr~I~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC56Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSS1_A. Any condition in the opinion of the Emergency Director that indicates Loss of theFuel Clad Barrier.POTENTIAL LOSS2A. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.Basis:Loss Threshold
#1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold
#2 BasisPotential Los 6. A.AThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-31EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC1Initiating Condition:
RCS or SG Tube LeakageOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSSA-.1 .AA Aautomatic or manual EGGS -(S0)ESAS actuation is required by EITHER of thefollowing:
ag. UNISOLABLE RCS leakageOR!22. Steam Generator tube RUPTURE.POTENTIAL LOSS2. UNISOLABLE RCS leakage > 150,qpm.OR3. HPI-PORV Cooling in effect.OR4. a. RCS Pressure
> 2450 psic.ANDb. RCS Pressure not lowering.
OQperation of a standby charging (makeup) pum Ncrqired by EITHER ofthfollowing.-!.
[- S leakageSG tube leakage.B1. .RCS coldWnr rFate greater than (site pe,;ifi, thermal -hockcicra'imtcdefined by ciGseii indicatienc Month 20XXTMI 3-32EP-AA-1009 (Revision XX)
Throa MUil WaIndl Qtztinn AnnoiyFyalnn NnnlanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION mm *
* li'A" *3i. I-". !ntO*::ltV
.I.too entr conat....
motIBasis:UNISOLABLE:
An open or breached system line that cannot be isolated, remotely orlocally.RUPTURE(D):
The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety iniection.
FAULTED:
The term aDDlied to a steam aenerator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.
Loss Threshold
#1 BasisLosse-1AThis threshold is based on an UNISOLABLE RCS leak of sufficient size to require anautomatic or manual actuation of the Emergency Core Cooling System (ECCS). Thiscondition clearly represents a loss of the RCS Barrier.This threshold is applicable to unidentified and pressure boundary
: leakage, as well asidentified leakage.
It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location
-inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.
A steam generator with primary-to-secondary leakage of sufficient magnitude to requirea safety injection is considered to be RUPTURED.
If a RUPTURED steam generator isalso FAULTED outside of containment, the declaration escalates to a Site AreaEmergency since the Containment Barrier CT1 Loss threshold 1-A-will also be met.Potential Loss Threshold
#2 BasisPotential Lss 1 .AThis threshold is based on an UNISOLABLE RCS leak that results in the inability tomaintain pressurizer level within specified limits by operation of a normally usedcharging (makeup) pump, but an ECCS (SI) actuation has not occurred.
The threshold is met when an operating procedure, or operating crew supervision, directs that astandby charging (makeup) pump be placed in service to restore and maintainpressurizer level.Month 20XXTMI 3-33EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION This threshold is applicable to unidentified and pressure boundary
: leakage, as well asidentified leakage.
It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location
-inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.
If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold CT1 .A-will also be met.Potential Loss Threshold
#3 BasisPatontial I o-.c 1 RThis condition indicates an extreme challenge to the integrity of the RCS pressureboundary due to pressurized thermal shock -a transient that causes rapid RCScooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-002 Loss of 250F Subcooled Margin4. OP-TM-MAP-D031, MU Flow HI5. OP-TM-EOP-005, OTSG Tube LeakageMonth 20XXTMI 3-34EP-AA-1 009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC2Initiating Condition:
Inadequate Heat RemovalOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSSA.HPI-PORV Cooling in effectinadequate ROS ho-at .mo.a. capability
,ia stoam g.n.rato..
as indicated by i;,cpociftcidctoc Basis:There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisPotential Loss 2.-AHPI-PORV Cooling in effect indicates a Lack of Primary to Secondary Heat Transfercapability.
This condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier.
In accordance with EOPs, there may beunusual accident conditions during which operators intentionally reduce the heatremoval capability of the steam generators; during these conditions, classification usingthreshold is not warranted.
Meeting this threshold results in a Site Area Emergency because this threshold isidentical to Fuel Clad Barrier FC2 Potential Loss Tthreshold 2-#8#3; both will be met.This condition warrants a Site Area Emergency declaration because inadequate RCSheat removal may result in fuel heat-up sufficient to damage the cladding andi,,reaseraise RCS pressure to the point where mass will be lost from the system.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-004, Lack of Primary to Secondary Heat TransferMonth 20XXTMI 3-35EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC3Initiating Condition:
Containment Radiation
/ RCS ActivityOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSSA. Containment radiation monitor reading grato, than (RM-G-22 or RM-G-23) reading >25 R/hr.-.(site specific value).Basis:Loss Threshold BasisThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equalsTechnical Specification allowable limits. This value is lower than that specified for FuelClad Barrier FC3 Loss Tthreshold 3-.A#1 since it indicates a loss of the RCS Barrieronly.I There is no RCS Potential Loss threshold associated with RCS Activity
/ Containment Radiation.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor ReadingIndicative of Loss of RCS BarrierMonth 20XXTMI 3-36EP-AA-1009 (Revision XX)
IFvnlnn Nudla~rThrais Milp Island Station Annax Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC56Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSSI1_A. Any condition in the opinion of the Emergency Director that indicates Loss of theRCS Barrier.POTENTIAL LOSS2B. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis:Loss Threshold
#1 BasisLsse-&AThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is lost.Potential Loss Threshold
#2 Basis6. A-This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-37EP-AA-1 009 (Revision XX)
Throm Uila lainnei Qtatinn AnnoyF:Yalnn N, nrlanrTurn, MiI~ It6nrl ~tmtinn Ann.v Fv.Inn Mmu~I~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT1Initiating Condition:
RCS or SG Tube LeakageOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSSA. A leaking or RUPTURED SG is FAULTED outside of containment.
: 1. SG tube leakage > 150prmAND2. SG is FAULTED outside of containment.
Basis:RUPTURE(D):
The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety iniection.
FAULTED:
The term applied to a steam generator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.
Loss Threshold BasisThis threshold addresses a leaking or RUPTURED Steam Generator (SG) that is alsoFAULTED outside of containment.
The condition of the SG, whether leaking orRUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1Potential Loss Threshold 2.b 4-A and Loss Threshold 1.b-A, respectively.
This condition represents a bypass of the containment barrier.FAULTED is a defined term within the NEI 99-01 methodology; this determination is notnecessarily dependent upon entry into, or diagnostic steps within, an EOP. Forexample, if the pressure in a steam generator is decreasing uncontrollably
[part of theFAULTED definition]
and the faulted steam generator isolation procedure is not enteredbecause EOP user rules are dictating implementation of another procedure to address ahigher priority condition, the steam generator is still considered FAULTED foremergency classification purposes.
The FAULTED criterion establishes an appropriate lower bound on the size of a steamrelease that may require an emergency classification.
Steam releases of this size arereadily observable with normal Control Room indications.
The lower bound for thisaspect of the containment barrier is analogous to the lower bound criteria specified in ICMonth 20XXTMI 3-38EP-AA-1009 (Revision XX)
NuclearThropu MiIA 1-cland Atnatinn Annex Exelnn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION BRSU3 for the fuel clad barrier (i.e., RCS activity values) and IC MSU64 for the RCSbarrier (i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steamgenerator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant andsustained release of radioactive steam to the environment (and are thus similar to aFAULTED condition).
The inability to isolate the steam flow without an adverse effecton plant cooldown meets the intent of a loss of containment.
Steam releases associated with the expected operation of a SG power operated reliefvalve or safety relief valve do not meet the intent of this threshold.
Such releases mayoccur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stablecondition and prepare to initiate a plant cooldown.
Steam releases associated with theunexpected operation of a valve (e.g., a stuck-open safety valve)-dG meets thisthreshold.
Following an SG tube leak or rupture, there may be minor radiological releases througha secondary-side system component (e.g., air ejectors, glad seal exhausters, valvepacking, etc.). These types of releases do not constitute a loss or potential loss ofcontainment but should be evaluated using the Recognition Category BA lCs.The emergency classification levels resulting from primary-to-secondary
: leakage, withor without a steam release from the FAULTED SG, are summarized below.Month 20XXTMI 3-39EP-AA-1009 (Revision XX)
Throm Milo Ilainel ~tatinn AnnoyvF:yalnn Nwlona~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Affected SG is FAULTEDOutside of Containment?
P-to-S Leak Rate Yes NoLess than or equal to 25 No classification No classification gpm (Or othor value p. .SUW Do'v.'lepor Notes)Grete thanm 25 gpm (oGreater than 25 gpm(oOth'r v.,alue SU4Greater than 150 aDm.Unusual Event perSU4MU6Unusual Event perSU4MU6The capacity of one makeuppump in the normal Site Area Emergency charging mode is exceeded per FS1Requires operation of-aAlert per FA1pumpo(RCS BarrierPotential Loss)Requires an automatic ormanual EGGS (SI) actuation (RCS Barrier Loss)Site Area Emergency per FS1Alert per FA1There is no Potential Loss threshold associated with RCS or SG Tube Leakage.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-005, OTSG Tube Leakage4. OP-TM-EOP-001, Reactor TripMonth 20XXTMI 3-40EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExellon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT2Initiating Condition:
Inadequate Heat RemovalOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSSA. 1. (Site cpocific critercia forF Antry into core cooling roctoration procoduro)
AND2. RestorFation pmroedure not eftoctiI.oA Within 15 mninue1. Tcad > 1800&deg;FAND2. EOP Restoration procedures not effective in < 15 minutes.Basis:IMMINENT:
The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisPotential Loes 2.A.This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure.
For thiscondition to occur, there must already have been a loss of the RCS Barrier and the FuelClad Barrier.
If implementation of a procedure(s) to restore adequate core cooling is noteffective (successful) within 15 minutes, it is assumed that the event trajectory will likelylead to core melting and a subsequent challenge of the Containment Barrier.The restoration procedure is considered "effective" if core exit thermocouple readingsare decreasing and/or if reactor vessel level is increasing.
Whether or not theprocedure(s) will be effective should be apparent within 15 minutes.
The Emergency Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.
Severe accident analyses (e.g., NUREG-1 150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damagescenarios, and that the likelihood of containment failure is very small in these events.Given this, it is appropriate to provide 15 minutes beyond the required entry point todetermine if procedural actions can reverse the core melt sequence.
Month 20XXTMI 3-41EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-008, RCS Superheated
: 3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-006, LOCA CooldownMonth 20XXTMI 3-42EP-AA-1 009 (Revision XX)
E~xAlnn NudlanrThrogm RAilas Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT3Initiating Condition:
Containment Radiation
/ RCS ActivityOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSSAX Containment radiation monitor roading gr.ator than (RM-G-22 or RM-G-23) reading >4.40E+03 R/hr.(scite sp.cifc value).Basis:There is no Loss threshold associated with RCS Activity
/ Containment Radiation.
Potential Loss Threshold BasisPotontial Loss 3. AThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that 20% of the fuel cladding has failed.This level of fuel clad failure is well above that used to determine the analogous FuelClad Barrier Loss and RCS Barrier Loss thresholds.
NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protective actions.
For this condition to exist, there must already have been a loss of the RCSBarrier and the Fuel Clad Barrier.
It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classification level to a General Emergency.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. Core Damage Assessment Methodology (CDAM)Month 20XXTMI 3-43EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Initiating Condition:
Containment Integrity or BypassOperating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSSCT41A. Containment isolation is required AND EITHER of the following:
a4-. UNPLANNED deGrease-lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Directors judgmentthat indicate a loss of containment integrity.
ORb2. UNISOLABLE pathway from containment to the environment exists.OR28. Indication of RCS leakage outside of containment POTENTIAL LOSSJA nmnerI-Orising.OR48. Explosive mnixtureContainment
> 4%.ORnIY conaiiionS menieacior BuilOing pressure
> 5o pslg andexists inside containment..
Hydrogen Concentration in5G. al-. GentainmeFt-Reactor Building pressure greater than (site spe.ifi; pressuresetp t> 30 osiciANDb2. ILees~ than one full train of (site sepoific.
Syrtcm Or equipment) is operating per deign for 15 "min, ute or longer. Reactor Building Emerqency Cooling is lessthan ANY one of the following conditions.
SPRAY COOLERS2 00 31 1Basis:FAULTED:
The term aDDlied to a steam aenerator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.
Month 20XXTMI 3-44EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.UNISOLABLE:
An open or breached system line that cannot be isolated, remotely orlocally.LossThreshold
#1 Basis:L-ess-4.These thresholds address a situation where containment isolation is required and one oftwo conditions exists as discussed below. Users are reminded that there may beaccident and release conditions that simultaneously meet both loss thresholds 1.a4--A4and 1.b4.A2.1 .a4 A I -Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referredto as design leakage).
Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop incontainment pressure.
Recognizing the inherent difficulties in determining acontainment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given tocurrent plant conditions, and available operational and radiological data (e.g.,containment
: pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).Refer to the middle piping run of Figure 9-F-4. Two simplified examples are provided.
One is leakage from a penetration and the other is leakage from an in-service systemvalve. Depending upon radiation monitor locations and sensitivities, the leakage couldbe detected by any of the four monitors depicted in the figure.Another example would be a loss or potential loss of the RCS barrier, and thesimultaneous occurrence of two FAULTED locations on a steam generator where onefault is located inside containment (e.g., on a steam or feedwater line) and the otheroutside of containment.
In this case, the associated steam line provides a pathway forthe containment atmosphere to escape to an area outside the containment.
Following the leakage of RCS mass into containment and a rise in containment
: pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.
Thesereleases do not constitute a loss or potential loss of containment but should beevaluated using the Recognition Category RA ICs.1 -Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment.
As usedhere, the term "environment" includes the atmosphere of a room or area, outside thecontainment, that may, in turn, communicate with the outside-the-plant atmosphere Month 20XXTMI 3-45EP-AA-1009 (Revision XX)
Thrno Wig% Ilainni Qtafinn AnnovFvalnn TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION (e.g., through discharge of a ventilation system or atmospheric leakage).
Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.
Refer to the top piping run of Figure 9-F-4. In this simplified
: example, the inboard andoutboard isolation valves remained open after a containment isolation was required (i.e.,containment isolation was not successful).
There is now an UNISOLABLE pathwayfrom the containment to the environment.
The existence of a filter is not considered in the threshold assessment.
Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Leakage between two interfacing liquid systems, by itself, does not meet this threshold.
Refer to the bottom piping run of Figure 9-F-4. In this simplified
: example, leakage in anRCP seal cooler is allowing radioactive material to enter the Auxiliary Building.
Theradioactivity would be detected by the Process Monitor.
If there is no leakage from theclosed water cooling system to the Auxiliary
: Building, then no threshold has been met.If the pump or system piping developed a leak that allowed steam/water to enter theAuxiliary
: Building, then loss threshold 2_4B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the fourmonitors depicted in the figure and cause threshold 1 .a4A4 to be met as well.Following the leakage of RCS mass into containment and a rise in containment
: pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.
Minorreleases may also occur if a containment isolation valve(s) fails to close but thecontainment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category RA ICs.The status of the containment barrier during an event involving steam generator tubeleakage is assessed using Containment Barrier CT1 Loss lthreshold-l-A.
Loss Threshold
#2 Basis:L4e66-4.B Containment sump, temperature, pressure and/or radiation levels will inGoeaserise ifreactor coolant mass is leaking into the containment.
If these parameters have notincreased, then the reactor coolant mass may be leaking outside of containment (i.e., acontainment bypass sequence).
IFiGeaseRaises in sump, temperature,
: pressure, flowand/or radiation level readings outside of the containment may indicate that the RCSmass is being lost outside of containment.
Month 20XXTMI 3-46EP-AA-1 009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Unexpected elevated readings and alarms on radiation monitors with detectors outsidecontainment should be corroborated with other available indications to confirm that thesource is a loss of RCS mass outside of containment.
If the fuel clad barrier has notbeen lost, radiation monitor readings outside of containment may not inareaserise significantly;
: however, other unexpected changes in sump levels, area temperatures orpressures, flow rates, etc. should be sufficient to determine if RCS mass is being lostoutside of the containment.
Refer to the middle piping run of Figure 9-F-4. In this simplified
: example, a leak hasoccurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.
Depending upon radiation monitor locations and sensitivities, the leakage could bedetected by any of the four monitors depicted in the figure and cause loss threshold 1 .a4.A-.-
to be met as well.To ensure proper escalation of the emergency classification, the RCS leakage outsideof containment must be related to the mass loss that is causing the RCS Barrier RClLoss Threshold 1.a and/or Potential Loss threshold 2.a-l-A to be met.Potential Loss Threshold
#3 BasisPtentiaI Less 4. AIf containment pressure exceeds the design pressure, there exists a potential to lose theContainment Barrier.
To reach this level, there must be an inadequate core coolingcondition for an extended period of time; therefore, the RCS and Fuel Clad barrierswould already be lost. Thus, this threshold is a discriminator between a Site AreaEmergency and General Emergency since there is now a potential to lose the thirdbarrier.Potential Loss Threshold
#4 BasisPotential Loss 4.1.The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity.
Ittherefore represents a potential loss of the Containment Barrier.Potential Loss Threshold
#5 BasisPotontial L-se 4.GThis threshold describes a condition where containment pressure is greater than thesetpoint at which containment energy (heat) removal systems are designed toautomatically
: actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually startequipment that may not have automatically
: started, if possible.
This threshold represents a potential loss of containment in that containment heatremoval/depressurization systems (e.g., containment sprays, ice condenser fans, etc.,Month 20XXTMI 3-47EP-AA-1009 (Revision XX)
Throo Milo Icinnel Qtnfinn AnnovF:valnn Iw-la~l rThr~ Miki IQI~nrI ~t~tinn Ann~v Fv~Inn Miir~I~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION but not including containment venting strategies) are either lost or performing in adegraded mannerBasis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-32. FSAR Section 6.6 Reactor Building Pressure-Time Response3. Technical Specifications 3.5.3, Engineered Safeguards Protection SystemActuation Setpoints
: 4. FSAR Section 6.3.3, Actuation
: 5. FSAR Section 6.5.3, Hydrogen Generation
: 6. OP-TM-EOP-006, LOCA Cooldown7. 1302-5.25 Reactor Building Sump Level8. FSAR Section 5.2 Reactor Building9. FSAR Section 9.2, Chemical Addition and Sampling System10. OP-TM-EOP-002, Loss of 250F Subcooling Margin11. OP-TM-EOP-006, LOCA Cooldown12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs13. OP-TM-MAP-D0301, High Make-up FlowMonth 20XXTMI 3-48EP-AA-1009 (Revision XX)
Tknagi RAHft Id.-AftrvA Q*-m*mon AnniawIvaletn Mmrai lnarIEEE ~ EVIIE~ U~E~E E~4 ~ U I~EEE E~*~ ~~~~U~SU U ***TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT56Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2,3,4Fission Product Barrier (FPB) Threshold:
LOSS.1A. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSS28. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis:Loss Threshold
#1 BasisLOesS-6This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is lost.Potential Loss Threshold
#2 BasisPotential Loss 6.,AThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-50EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG1Initiating Condition:
Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the General promptlyupon determining that (cite cp-.ifi,"
hou .r,) the applicable time has beenexceeded, or will likely be exceeded.
1--a-. Loss of ALL offsite and ALL , n"it; AC power to (Sit .specific egencybuses)Emeraencv 4KV buses.2.ANDFailure of EG-Y-1 A, EG-Y-11B Emerqency Diesel Generators and EG-Y-4 SBO.Diesel Generator to supply power to Emergency 4KV buses.AND3b. EITHER of the following:
: a. Restoration of at least one emer4eRey-Emergency 4KV bus in < 4 hours isthan (site specific hourS) i. n likely.ORb. > 250F superheat p
* I *Ill m I I It~ite sE~ocmc inaication oran ina~iiitv toaaoeauateiv remove noa;t mrnrom o orc* lJBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or lacin it in the cold shutdown condition, including the ECCS.These aretypically systems classified as safety-related.
This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heatremoval/pressure
: control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of oRe rOmoroa ny fission productMonth 20XXTMI 3-51EP-AA-1009 (Revision XX) hrom Wha lalanri tatinn AnnovF::alnn Tkrn~ MiI~ Iokanrl ~hatinn Ann.v FvInn fJmur~I.~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS barriers.
In addition, fission product barrier monitoring capabilities may be degradedunder these conditions.
The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. This will allow additional time for implementation of offsiteprotective actions.Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andevent trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.
The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.
Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade.
The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The emergency busses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.
Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SG12. OP-TM-EOP-01 0 Emergency Procedure Rules, Guides And Graphs3. FSAR Section 8.2.2 Unit Distribution System4. FSAR Section 8.2.3 Sources of Auxiliary Power5. FSAR Section 8.5 Station Blackout6. Technical Specification Section 3.7, Unit Electric Power System7. 1107-1 Normal Electrical System8. 1107-2A Emergency Electrical
-4KV and 480 Volt9. OP-TM-AOP-020 Loss Of Station Power10. 1107-3 Diesel Generator
: 11. 1107-9 SBO Diesel Generator
: 12. OP-TM-EOP-008 RCS Superheated
: 13. OS-24, Conduct of Operation during Abnormal and Emergency EventsMonth 20XXTMI 3-52EP-AA-1 009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS1Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Sito Arop E..ergencyevent promptlyupon determining that the applicable time 4-5-inutes-has been exceeded, or willlikely be exceeded.
: 1. Loss of ALL offsite and ALL ,n-it, AC Power to (;ito ..p.ific oFmo.gon..Y buses)Emergency 4KV buses for 15 minutec Or longR. .AND2. Failure of EG-Y-1A, EG-Y-11B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from thetime of loss of both offsite and onsite AC power.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure
: control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions.
This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.The emergency busses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.
Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.Month 20XXTMI 3-53EP-AA-1009 (Revision XX)
Throa Wig% lalanfi Qfafinn AnngvFvalnn .iollarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RAG 1, FG1. e--MSG11or MG2.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS12. FSAR Section 8.2.3, Sources of Auxiliary Power3. Technical Specification Section 3.7, Unit Electric Power System4. 1107-1 Normal Electrical System5. 11 07-2A Emergency Electrical
-4KV and 480 Volt6. OP-TM-AOP-020 Loss Of Station Power7. 1107-3 Diesel Generator
: 8. 1107-9 SBO Diesel Generator
: 9. FSAR Section 8.2.2, Unit Distribution System10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-54EP-AA-1 009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA1Initiating Condition:
I Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAleFt promptly upondetermining that the applicable time 16 r:inutes-has been exceeded, or will likelybe exceeded.
1.AC power capability to Emergency 4KV buses reduced to only one of the following power sources for > 15 minutes." Auxiliary Transformer 1 A" Auxiliary Transformer 1 B* Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1 B" SBO Diesel Generator EG-Y-4a. AC power vapability' to buses) is reduced to a singl.9ower source for 15 minutes Or longer.AND2b. Any additional single power source failure will result in a loss of all-ALL AC powerto SAFETY SYSTEMS.Basis:SAFETY SYSTEM: A svstem reauired for safe Dlant operation, cooling down the plantand/or Dlacina it in the cold shutdown condition.
includina the ECCS.These areItypically systems classified as safety-related.
This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS.
In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.
This IC provides an escalation path from ICMSUI.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.Month 20XXTMI 3-55EP-AA-1009 (Revision XX) hrgaia Wha lalanA Qtatinn AnnovP::ainn Throo Milo IeIonrI Qtoti,~n Annoy Fv~Inn NmIr~I~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS e A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).
e A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.
9 A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MSS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA12. FSAR Section 8.2.3, Sources of Auxiliary Power3. FSAR Section 8.5, Station Blackout4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical
-4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator
: 9. 1107-9 SBO Diesel Generator
: 10. FSAR Section 8.2.2, Unit Distribution SystemMonth 20XXTMI 3-56EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU1Initiating Condition:
Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual E'-entevent promptly upondetermining that the applicable time 1-6 Finutes-has been exceeded, or will likelybe exceeded.
1-. Loss of ALL offsite AC power capability to Emergency 4KV buses (site-speGifi emcrgoncy b.. ) , for _> 15 minutes-er-feng.
Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification
: purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it.The emergency busses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.
Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MSA1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SUW2. FSAR Section 8.2.3, Sources of Auxiliary Power3. Technical Specification Section 3.7, Unit Electric Power System4. 1107-1 Normal Electrical System5. 11 07-2A Emergency Electrical
-4KV and 480 Volt6. OP-TM-AOP-020 Loss Of Station Power7. 1107-3 Diesel Generator
: 8. 1107-9 SBO Diesel Generator Month 20XXTMI 3-57EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS
: 9. FSAR Section 8.2.2, Unit Distribution SystemMonth 20XXTMI 3-58EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG28Initiating Condition:
Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Genoral ,, ,.,-ge..yevent promptlyupon determining that the applicable time 46-eninutes-has been exceeded, or willlikely be exceeded.
: 1. Loss of ALL offsite AC power to Emerqency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emerqency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Voltage is < 105 VDC on1 25 VDC Distribution System 1 A and 1 B.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1. a. Los o _6ef ALL-'-e of 6it. a:;n di A LL onsite AG power to (eitc specific omergeFncy
-buses) for 15 mninutes or longer-.ANDb. Indicated voltage is less than (site-specific bus voltage value) onAL(site sp;cific; Vital D- busses) for 15 r Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretvpicallv systems classified as safetv-related.
Month 20XXTMI 3-59EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heatremoval/pressure
: control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS.
Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.
Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when beth-allEALs thleshelds-are met.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SG82. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System Failure6. FSAR Section 8.2.2, Unit Distribution System7. FSAR Section 8.2.3, Sources of Auxiliary Power8. Technical Specification Section 3.7, Unit Electric Power System9. 1107-1 Normal Electrical System10. 11 07-2A Emergency Electrical
-4KV and 480 Volt11. OP-TM-AOP-020 Loss Of Station Power12. 1107-3 Diesel Generator
: 13. 1107-9 SBO Diesel Generator
: 14. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-60EP-AA-1009 (Revision XX) krAmg% Rfiligh lalonA Ctotinn AnniavIPvgmlen khaot--mar lkm~ I ll a WI QVliruil B "IlIAn a vninM lar*U1 *1U *usu ,. uu. flu ul. ll Iut.I.I..I TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS28Initiating Condition:
Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Aroa Em...ge..yevent promptlyupon determining that the applicable time 45-inutes--has been exceeded, or willlikely be exceeded.
vVoltage is < 105 VDC loss than (site spocific b.us125 VDC Distribution System 1A and 11B ALL (sit -sp'. .fiG ">15 minutes-er-IGRleF.
Ivoltage value)- novital DG bussee4 forBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC addresses a loss of Vital DC power which compromises the ability to monitorand control SAFETY SYSTEMS.
In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient losses.Escalation of the emergency classification level would be viaMSG3.or momentary powerICs RAG1, FG1 orBasis Reference(s):
: 1. NEI 99-01 Rev 6, SS82. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System FailureMonth 20XXTMI 3-61EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS36Initiating Condition:
Inability to shutdown the reactor causing a challenge to core cooling or RCS heatremoval.Operating Mode Applicability:
1,2Emergency Action Level (EAL):1. Automatic or Manual Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. All-ALL manual actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 5%.AND3. EITHER of the following conditions exist:a. Tclad > 14000F.ORb. HPI-PORV Cooling in effect-.fl!A...a. cakeO sDCCITI indirtcaliiun of an inability to adequately rumuve nueat irumA Me GOrci--" \ ..... r ......-4' --1 ....... jORL.. / ','1-. laiw eciiic~m inudaiurime of aR nauniw it touueuateiv Fefflve i4A--4 'rUNM I.-lII IBasis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, all subsequent operator manual actions,both inside and outside the Control Room including driving in control rods and boroniniection~all operator to mnaually shutdown the areunsuccessful, and continued power generation is challenging the capability toadequately remove heat from the core and/or the RCS. This condition will lead to fuelMonth 20XXTMI 3-62EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS damage if additional mitigation actions are unsuccessful and thus warrants thedeclaration of a Site Area Emergency.
In some instances, the emergency classification resulting from this IC/EAL may behigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs.
This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor.
The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Escalation of the emergency classification level would be via IC RAG1 or FGI.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS52. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer3. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-001, Reactor Trip5. 1102-4 Power Operation
: 6. OP-TM-641
-000- Reactor Protection System (RPS/DSS)
Month 20XXTMI 3-63EP-AA-1 009 (Revision XX)
Throp Milo haland qtatinn AnnoyThre Mil I~Iunr ~tiatin Annv Feinn NuclesarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA36Initiating Condition:
Automatic or manual trip fails to shutdown the reactor, and subsequent manual actionstaken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:
1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
: 1. A.-aAutomatic OF-manual[Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. Manual actions taken at the r.a.tO. cOntrol'
.onsolConsole Center-are notsuccessful in shutting down the reactor as indicated by Reactor Power > 5%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic Omanalreactor trip that results in a reactor shutdown, and subsequent operator manual actionstaken at the Console Center roactor control concolo to shutdown the reactor are alsounsuccessful.
This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor controlconsoles since this event entails a significant failure of the RPS.A manual action at the Console Center reactOr contro! coco!oc is any operator action,or set of actions, which causes the control rods to be rapidly inserted into the core (e.g.,initiating a manual reactor trip. This action does not include manually driving in controlrods or implementation of boron injection strategies.
If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away fromthe Console Center reactor control conGelos (e.g., locally opening breakers).
Actionstaken at back-panels or other locations within the Control Room, or any location outsidethe Control Room, are not considered to be "at the Console Centerro.acto controlGOR60Gee6".
The plant response to the failure of an automatic eF manual-reactor trip will vary basedupon several factors including the reactor power level prior to the event, availability ofthe condenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If the failure to shutdown the reactor is prolonged enough to cause achallenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XXTMI 3-64EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclea~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS I classification level will escalate to a Site Area Emergency via IC MSS_3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. AbsentI the plant conditions needed to meet either IC MSS36 or FS1, an Alert declaration isappropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.
I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA52. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer3. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-001, Reactor Trip5. 1102-4 Power Operation
: 6. OP-TM-641-000-Reactor Protection System (RPS/DSS)
Month 20XXTMI 3-65EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU36Initiating Condition:
Automatic or manual trip fails to shutdown the reactor.Operating Mode Applicability:
1,2Emergency Action Level (EAL):I Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
1.a. Ar,-aAutomatic Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.ANDb. A-sSubsequent manual action taken at the rcactOr control concolocConsole Center is successful in shutting down the reactor.ORa. A-fAManual Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2.b. EITHER of the followingt
--J. ..... A----I ..... I---- ;---i- uDaseuentl manual aciion taken at -R murasaar cnuolm.-
cn-nniec I-S ! ; t, 14SUEPE785 u " 6 utt "iq OWR Me FeaSIONOR2. A sSubsequent automatic Ttrip is successful in shutting down thereactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, and either a subsequent operator manualMonth 20XXTMI 3-66EP-AA-1009 (Revision XX)
Throm Mu.la li.nnri Qtafin AnnoyF:valnn Nain-loar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS action taken at the Console Center reactor control consoles or an automatic trip issuccessful in shutting down the reactor.
This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor trip, operators will promptly initiate manualactions at the Console Center reactor control consolos to shutdown the reactor (e.g.,initiate a manual reactor trip). If these manual actions are successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.EAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly tako.n uaaction at anotherl c-ation(s) on the reactor control consoles to shutdown the '.roct.(n._-._ initiato a man,-al macfor trio a diffcrmnt c,;.tch\..
D ..n...ina..
un.........n.
c.v.r.f...........
, .... ,.,....-
..-.-. .--.... ... -----.......-
&#xf7;-; --.-....'.c concurren plantIfactors, tho initial or subsequent eeffot to manually trip the roactOr, or a concurrent plantcondition, may lead to the generation of an automatic reactor trip signal. If asubsequent manul- OF automatic trip is successful in shutting down the reactor, coreheat generation will quickly fall to a level within the capabilities of the plant's decay heatremoval systems.A manual action at the Console Center rcactOr control consolSG is any operator action,or set of actions, which causes the control rods to be rapidly inserted into the core (e.g.,initiating a manual reactor trip). This action does not include manually driving in controlrods or implementation of boron injection strategies.
Actions taken at back-panels orother locations within the Control Room, or any location outside the Control Room, arenot considered to be "at the Console Center reactor control consoles".
The plant response to the failure of an automatic or manual reactor trip will vary basedupon several factors including the reactor power level prior to the event, availability ofthe condenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If subsequent operator manual actions taken at the Console Centerreactor control consolcs are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC M.A36. Depending uponthe plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MSA36 or FA1, an Unusual Event declaration is appropriate for this event.I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
I Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpointtesting),
the following classification guidance should be applied.Month 20XXTMI 3-67EP-AA-1009 (Revision XX)
Throp Milo Inland qtafinn AnnpvThrg~ M~ci ~I~d ~mtin An~'tExellnn Nuclea~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS
" If the signal generated as a result of plant work causes a plant transient that createda real condition that should have included an automatic reactor trip and the RPS failsto automatically shutdown the reactor, then this IC and the EALs are applicable, andshould be evaluated.
" If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS trip signal and the trip failure is determined throughother means (e.g., assessment of test results),
then this IC and the EALs are notapplicable and no classification is warranted.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU52. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-001, Reactor Trip4. 1102-4 Power Operation
: 5. OP-TM-641
-000- Reactor Protection System (RPS/DSS)
Month 20XXTMI 3-68EP-AA-1009 (Revision XX)
Throm Uila lainnel Qtatinn AnnoyF::alnn NiiIe-lar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA42Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.
Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAled promptly upondetermining that the applicable time 45-*i utes-has been exceeded, or will likelybe exceeded.
: 1. a. AR,-UNPLANNED event results in the inability to monitor ANYone 9o MorTable Mlf t4he followi.ng parameters from within the Control Room for >15minutes O.lenge .r[,,e t.able belo-w][ PA[R parameter list;Reactor PowerRGS LeveiRCS PressureIn Corc/Corc ExitT-empeatufe Table M1 Control Room Parameters
" Reactor Power" PZR Level" RCS Pressure* In Core/Core Exit Temperature
" Level in at least one OTSG" OTSG Emergency Feed Water FlowLev.'Io in a t I es (site specif icnumber) steam; ge-nerators Steam GeneratorAuxiliary orEneCem e Fee mooC A'A ,at F low.ANDb. Any Table M2Wf the transient eveRts in progress.
0 Is^rv% ^ ^ lft iif r11% ft, r ^r trmrr"!%
r ft-e-r IA .Ar- 4..4Ia l,.4 -n..~.4a.
+k.. Or-O/ ..11 1 6A ! !,~ lA.... r ......ReaeWF4p ot 'a" gro -- r .. .--I -.UM W. "- "- .70 Ct toct0 RO:Tii;i "I"Month 20XXTMI 3-69EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Table M2 Significant Transients
" Automatic Turbine Runback >25% thermalreactor power" Electrical Load Rejection
>25% full electrical load" Reactor Trip" ESAS Actuation
" Thermal Power oscillations
> 10%Basis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced.
It thus represents a potential substantial degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for ono Or moroany ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s).
For example, the reactor power level cannot be determined from anyanalog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required.
The event would be reported if itsignificantly impaired the capability to perform emergency assessments.
In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective actiondecision-making.
Month 20XXTMI 3-70EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS I This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity
: control, core cooling and RCS heat removal.
The loss ofI the ability to determine one o Fnor-anv of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.
InI addition, if all indication sources for one OF or-eany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
Escalation of the emergency classification level would be via ICs FS1 or IC RAS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA2Month 20XXTMI 3-71EP-AA-1 009 (Revision XX)
IExelon NuclearThree Mile Islamnd S~tation Annex Exelon NucleanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU42Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Unu-'-ual Evcntcvent promptly upondetermining that the applicable time been exceeded, or will likelybe exceeded.
a- A-UNPLANNED event results in the inability to monitor one OrFmoMr ANY Table M1parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters
" Reactor Power* RCS Level" RCS Pressure" In Core/Core Exit Temperature
* Level in at least one OTSG.* OTSG Emeraency Feed Water Flow1. of the following Darametercs from within the Contro!1 Room for 15 minutocOF 4OAgef.Month 20XXTMI 3-72EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Month 20XXTMI 3-73EP-AA-1009 (Revision XX)
I=xelon NuclearThr~a Milp 11--aland Station Annex Exelnn NucleIAar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Basis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.I As used in this EAL, an "inability to monitor" means that values for one Or morangy ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s).
For example, the reactor power level cannot be determined from anyanalog, digital and recorder source within the Control Room.I An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required.
The event would be reported if itsignificantly impaired the capability to perform emergency assessments.
In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective actiondecision-making.
I This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity
: control, core cooling and RCS heat removal.
The loss ofthe ability to determine one O mer-eany of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.
InI addition, if all indication sources for one Or morany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
I Escalation of the emergency classification level would be via IC MSA42.Month 20XXTMI 3-74EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU2Month 20XXTMI 3-75EP-AA-1009 (Revision XX)
ExAIon NuclearThrpp Mile Island Stsation Annaex Exelon Nucle~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA59Initiating Condition:
I Hazardous event affecting a SAFETY SYSTEM needd -required for the currentoperating mode.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):( .1-.a The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)
" Internal or external flooding event" High winds or tornado strike" FIRE* EXPLOSION
-(,ito ,p ,,ific haza, dc)* Other events with similar hazard characteristics as determined by theShift ManagerANDEITHER of the following:
a.4, Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed-required byTechnical Specifications for the current operating mode.ORb.. 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure-neededrequired by Technical Specifications for the current operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if larqe quantities of smoke and heat areobserved.
EXPLOSION:
A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization.
A release of steam (from highenerav lines or comoonents) or an electrical comoonent failure (caused bv short circuits.
grounding.
arcing, etc.) should not automatically be considered an explosion.
SuchMonth 20XXTMI 3-76EP-AA-1009 (Revision XX)
Three Mile Islaind Stsatio~n Annex Exellon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the EGOS. These aretypically systems classified as safety-related.
VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements,
: testing, or analysis.
The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.
This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, needed-required for the currentoperating mode, "required",
i.e. required to be operable by Technical Specifications forthe current operating mode. This condition significantly reduces the margin to a loss orpotential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety eguipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL 4402.a BasisThis EAL addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is in since indications for it will be readily available.
The indications ofdegraded performance should be significant enough to cause concern regarding theoperability or reliability of the SAFETY SYSTEM train.EAL 1.b.2 2.b BasisThis EAL addresses damage to a SAFETY SYSTEM component that is- required to beoperable by Technical Specifications for the current operating mode, and is not inse wlee/operation or readily apparent through indications alone, of-as well as damage toa structure containing SAFETY SYSTEM components.
Operators will make thisdetermination based on the totality of available event and damage report information.
This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RASI.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):
: 1. NEI 99-01, Rev 6 SA9Month 20XXTMI 3-77EP-AA-1009 (Revision XX)
Throm Uila lalanel Atatinn Annowl::p~lnn N~nlaarThin. Mu. IQhanrI ~t~tinn Ann.v Fvp inn Niir~Iisnr TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU64Initiating Condition:
RCS leakage for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptly upondetermining that the applicable time 1456 -intes-has been exceeded, or will likelybe exceeded.
: 1. RCS unidentified or pressure boundary leakage gieateF-than
> 10 gpm for > 15 minutes.
(cito spcificvalue) for 15 minutoc Or longer-.OR2. RCS identified leakage >eateF thaR->25 gpm for>
.uFfor 15 .9Finutes or longer.OR3. Leakage from the RCS to a location outside containment
>25 gpm for > 15 minutes.groator than 25 gpmR for 15 minutes Or longer.Basis:UNISOLABLE:
An open or breached system line that cannot be isolated, remotely orlocally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 BasisThese EALs are focused on a loss of mass from the RCS due to "unidentified leakage",
"pressure boundary leakage" or "identified leakage" (as these leakage types are definedin the plant Technical Specifications).
EAL #3 BasisThis EAL addresses a RCS mass loss caused by an UNISOLABLE leak through aninterfacing system.These EALs thus apply to leakage into the containment, a secondary-side system (e.g.,steam generator tube leakage) or a location outside of containment.
Month 20XXTMI 3-78EP-AA-1009 (Revision XX)
ExAIon NuclearThreea Mile Island Station Annex Exelon NuclanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.
Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).
EAL #1 uses a lower valuethat reflects the greater significance of unidentified or pressure boundary leakage.The release of mass from the RCS due to the as-designed/expected operation of arelief valve does not warrant an emergency classification.
An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning asdesigned/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).
The 15-minute threshold duration allows sufficient time for prompt operator actions toisolate the leakage, if possible.
Escalation of the emergency classification level would be via lCs of Recognition Category RA or F.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU42. OP-TM-220-251 RCS Leak Rate Determination
: 3. OP-TM-220-252, Primary -To -Secondary Leakrate Determination
: 4. OP-TM-PRF1-0405 RB Sump Level HI5. UFSAR 6.4.3, Bases of Leakage Estimate6. UFSAR 6.4.4, Design Basis Leakage7. OP-TM-AOP-050, Reactor Coolant Leakage8. Technical Specification 3.1.6, Leakage and Table 4.1-2, Minimum Equipment Test Frequency Month 20XXTMI 3-79EP-AA-1009 (Revision XX)}}

Revision as of 14:56, 1 July 2018

Attachment 11: Discussion of Revision to the Radiological Emergency Plan Annex for Three Mile Island Nuclear Station, Cover Through Page TMI 3-79
ML14164A079
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 05/30/2014
From:
Exelon Generation Co
To:
NRC/FSME, Office of Nuclear Material Safety and Safeguards
Shared Package
ML14164A053 List:
References
RA-14-032, RS-14-115, TMI-14-046 EP-AA-1009, NEI 99-01, Rev. 6
Download: ML14164A079 (146)
v • d • e


Text

ATTACHMENT 11DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORTHREE MILE ISLAND NUCLEAR STATIONEP-AA-1 009Enclosures 000Enclosure 11 A -EAL Comparison Matrix DocumentEnclosure 11B -EAL Red-Line Basis DocumentEnclosure 11C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSATTACHMENT 11DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FORTHREE MILE ISLAND STATIONExelon Generation.

NEI 99-01 Rev 6 [Proposed EAL Justification AG1Initiating Condition

-GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mremTEDE or 5,000 mrem thyroid CDE.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.
  • The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 1000 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than5000 mrem for one hour of inhalation.

RG1Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1,000mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:

1,2,3.4,5,6,D Emergency Action Levels (EAL):Notes:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release pathto the environment is established.

If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15minutes.OR2. Dose assessment Using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate

> 5000 mRem CDEThyroid for 60 minutes of inhalation.

Table Ri Effluent Monitor Thresholds Effluent Monitor General Emergency RM-G-25 (Cond Offgas) 9.53 E+06 mR/hrRM-A-8GH (Station Vent) 3.09 E+05 cpmRM-G-24 (RB Purge) 5.55 E+05 mRPhrRM-A-14 (ESF Vent) 6.66 E+02 uCi/ccE No Change f Difference ElDeviation

1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
2) Added "Classification based on effluent monitor readings assumes that arelease path to the environment is established."

To the third bullet in order todelete the following from the basis section " Classification based on effluentmonitor readings assumes that a release path to the environment is established.

Ifthe effluent flow past an effluent monitor is known to have stopped due to actionsto isolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."

This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 11x17 procedure matrix used by the SM.Page 1 of 66 NEI 99-01 Rev 6 Proposed EAL j Justification AS1Initiating Condition

-SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mremTEDE or 500 mrem thyroid CDE.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptlyupon deterrining that the applicable time has been exceeded, or will likely beexceeded.

" if an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.

  • The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 100 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than500 mrem for one hour of inhalation.

RS1Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mRemTEDE or 500 mRem thyroid CDE.Operating Mode Applicability:

1,2,3,4,5,6,D Emergency Action Levels (EAL):D No Change E Difference 1 Deviation

1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
2) Added "Classification based on effluent monitor readings assumes that arelease path to the environment is established."

To the third bullet in order todelete the following from the basis section "Classification based on effluentmonitor readings assumes that a release path to the environment is established.

Ifthe effluent flow past an effluent monitor is known to have stopped due to actionsto isolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."

This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 1 1x17 procedure matrix used by the SM.Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

  • If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established.

If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyondthe site boundary of EITHER:a. >100mRemTEDE ORb. > 500 mRem CDE ThyroidOR3.. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate

> 500 mRem CDEThyroid for 60 minutes of inhalation.

ITable R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency RM-G-25 (Cond Offgas) 9.53 E+05 mR/hrRM-A-8GH (Station Vent) 3.09 E+04 cpmRM-G-24 (RB Purge) 5.55 E+04 mR/hrRM-A-14 (ESF Vent) 6.66 E+01 uCi/ccPage 2 of 66 NEI 99-01 Rev 6 ] Proposed EAL ] Justification AA1Initiating Condition

-ALERTRelease of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped dueto actions to isolate the release path, then the effluent monitor reading isno longer valid for classification purposes.
  • The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from adose assessment using actual meteorology are available.
1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site-specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 10mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Analysis of'a liquid effluent sample indicates a concentration orrelease rate that would result in doses greater than 10 mrem TEDEor 50 mrem thyroid CDE at or beyond (site-specific dose receptorpoint) for one hour of exposure.
4. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than50 mrem for one hour of inhalation.

RA1Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:

1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note:* The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected and the release start time is unknown, assumethat the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a releasepath to the environment is established.

If the effluent flow past an effluentmonitor is known to have stopped due to actions to isolate the release path, thenthe effluent monitor reading is no longer valid for classification purposes.

  • The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment using actual meteorology are available.
1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 60 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 60 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for >360 minutes.ORb. Analyses of field survey samples indicate a 60 mRem CDEThyroid for 60 minutes of inhalation.

Table R1 Effluent Monitor Thresholds Effluent Monitor AlertRM-G-25 (Cond Offgas) 9.53 E+04 mR/hrRM-A-8GH (Station Vent) 3.09 E+03 cpmRM-G-24 (RB Purge) 5.55 E+03 mR/hrRM-A-14 (ESF Vent) 6.66 E+00 uCi/ccH:1 No Change E Difference

-I- Deviation

1) Listed site-specific monitors and Threshold values to ensure timely classification.
2) Added "Classification based on effluent monitor readings assumes that a releasepath to the environment is established."

To the third bullet in order to delete thefollowing from the basis section "Classification based on effluent monitor readingsassumes that a release path to the environment is established.

If the effluent flowpast an effluent monitor is known to have stopped due to actions to isolate therelease path, then the effluent monitor reading is no longer valid for classification purposes."

This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 11x17 procedure matrix used by the SM.3) Calculations were performed, in accordance with (lA) guidance provided in NEI99-01 revision 6 EAL AA1, to determine the effluent monitor response for aradioactive liquid release and a WGDT release via the normal site release pathway.The release would contain activity equivalent to provide 10mrem TEDE or 50mremthyroid CDE at the site boundary.

The calculation determined the effluent monitorresponses would be >110% of the instruments maximum range and as such, lAWNEI 99-01 Rev 6 guidance, was not included in this EAL.Page 3 of 66 0NEI 99-01 Rev 6 Proposed EAL IJustification AU1Initiating Condition

-UNUSUAL EVENTRelease of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longerOperating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert promptly upondetermining that 60 minutes has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 60 minutes.* If the effluent flow past an effluent monitor is known to have stopped,indicating that the release path is isolated, the effluent monitor reading isno longer valid for classification purposes.
1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for"60 minutes orlonger:(site-specific monitor list and threshold values corresponding to 2 timesthe controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times thealarm setpoint established by a current radioactivity discharge permit for60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent releasecontrolling document limits) for 60 minutes or longer.RU1Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for60 minutes or longer.Operating Mode Applicability:

1, 2, 3,4,5, 6, DEmergency Action Levels (EAL):Note:* The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected andthe release start time is unknown,assume that the release duration has exceeded 60 minutes.* Classification based on effluent monitor readings assumes that a releasepath to the environment is established.

If the effluent flow past an effluentmonitor is known to have stopped due to actions to isolate the release path,then the effluent monitor reading is no longer valid for classification purposes.

1. Reading on ANY of the following effluent monitors

> 2 times alarmsetpoint established by a current radioactive release discharge permitfor a 60 minutes.* RM-L-6, Radwaste Discharge

  • RM-L-12, IWTS I IWFS Discharge
  • RM-A-7, Waste Gas Decay Tank Discharge
  • Discharge Permit specified monitorOR2. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60minutes.OR3. Confirmed sample analyses for gaseous or liquid releases indicateconcentrations or release rates > 2 times ODCM Limit with a releaseduration of Z 60 minutes.Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual EvetRM-G-25 (Cond Offgas) 1.09 E+03 mRlhrRM-A-8GH (Station Vent) 7.03 E+01 cpmRM-G-24 (RB Purge) 6.34 E+01 mR/hrRM-A-14 (ESF Vent) 7.60 E-02 uCi/cc1-No ChangeM Difference I Deviation
1) Listed site-specific monitors and Threshold values to ensure timely classification.
2) Added "Classification based on effluent monitor readings assumes that a releasepath to the environment is established."

To the third bullet in order to delete thefollowing from the basis section "Classification based on effluent monitor readingsassumes that a release path to the environment is established.

If the effluent flowpast an effluent monitor is known to have stopped due to actions to isolate therelease path, then the effluent monitor reading is no longer valid for classification purposes."

This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.Page 4 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AG2Initiating Condition

-- GENERAL EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.Operating Mode Applicability:

AllExample Emergency Action Levels:NOTES: The Emergency Director should declare the General Emergency promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded1. Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.RG2D No Change E Difference 1 Deviation

1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation
Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard forReliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedOctober 25,2012.Page 5 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification AS2Initiating Condition

-SITE AREA EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3description)

Operating Mode Applicability:

AllExample Emergency Action Levels:1 Spent fuel pool level cannot be restored to at least (site-specific Level 3description)

RS2D No ChangeFI- Difference 1 Deviation

1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation
Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard forReliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051) datedOctober 25,2012.Page 6 of 66 NEI 99-01 Rev 6 1Proposed EAL I Justification AAZInitiating Condition

-ALERTSignificant towering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2 or 3)1. Uncovery of irradiated fuel in the REFUELING PATHWAY.2. Damage to irradiated fuel resulting in a release of radioactivity from thefuel as indicated by ANY of the following radiation monitors:

(nite-specific listing of radiation

monitors, and the associated
readings, setpoints and/or alarms)3. Lowering of spent fuel pool level to (site-specific Level 2 value).RA2Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:

1, 2, 3, 4, 5, 6,DEmergency Action Levels (EAL):1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuelas indicated by ANY Table R1 Radiation Monitor reading >1000 mRem/hrD- No Change E Difference 1 Deviation

1) Listed site-specific monitors and Threshold values to ensure timely classification.
2) EAL #3 not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation
Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard forReliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedOctober 25,2012.Table R2Radiation MonitorsRMS Area Monitored ModeALLRM-G-9 FHB Bridge Rad Monitor5,6RM-G-6 RB Auxiliary Bridge Rad Monitor5,6RM-G-7 RB Main Bridge Rad MonitorPage 7 of 66 NEI 99-01 Rev 6 = Proposed EAL I Justification AU2Initiating Condition:

UNUSUAL EVENTUNPLANNED loss of water level above irradiated fuelOperating Mode Applicability:

AllExample Emergency Action Levels:1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:

(site-specific level indications).

ANDb. UNPLANNED rise in area radiation levels as indicated by ANY of thefollowing radiation monitors.

(site-specific list of area radiation monitors)

RU2Initiating Condition:

UNPLANNED loss of water level above irradiated fuelOperating Mode Applicability:

1,2, 3,4,5, 6, DEmergency Action Levels (EAL):I. a. UNPLANNED water level drop in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.No Change 1:1 Difference F Deviation

1) Listed site-specific level indication and monitors to ensure timely classification.

Table R2Radiation MonitorsRMS Area Monitored ModeALLRM-G-9 FHB Bridge Rad Monitor5,6RM-G-6 RB Auxiliary Bridge Rad Monitor5,6RM-G-7 RB Main Bridge Rad MonitorPage 8 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification AA3Initiating Condition

-ALERTRadiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.

Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2)Note: If the equipment in the listed room or area was already inoperable, or outof service, before the event occurred, then no emergency classification iswarranted 1 Dose rite greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)

2. An UNPLANNED event results in radiation levels that prevent orsignificantly impede access to any of the following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)

RA3Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.

Operating Mode Applicability:

1,2, 3, 4, 5. 6,DEmergency Action Levels (EAL):Note: If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification iswarranted

1. Dose rate greater than 15 mR/hr in ANY of the areas contained in Table R3:E No Change 1 Difference Deviation
1) Listed site specific plant rooms and areas with identified mode applicability toensure timely classification.

OR2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R4 plant rooms or areas:Table R4Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*

Modes 4, 5, and 6Intermediate Building*

Modes 4, 5, and 6Auxiliary Building*

Modes 4, 5, and 6Fuel Handling Building*

Modes 4, 5, and 6*Areas required to establish shutdown coolingPage 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU3Initiating Condition:

UNUSUAL EVENTReactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:1. (Site-specific radiation monitor) reading greater than (site-specific value).OR2. Sample analysis indicates that a reactor coolant activity value is greater thanan allowable limit specified in Technical Specifications.

RU3Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):1. Letdown Monitor RM-L-1 alert alanm (high or low channel).

OR2. Sample analysis indicates that:a. Dose Equivalent 1-131 specific coolant activity

> 60.0 uCilgm.ORb. Dose Equivalent XE-1 33 specific coolant activity> 797.0 uCi/gm.-- No Change M Difference F Deviation

1) Listed site-specific monitor and threshold value to ensure timely classification.
2) Listed this system category EAL in the radiological category EAL section tomaintain consistency with current and previous revisions of Exelon EALs. This willensure a timely classification since the threshold values are more aligned with theradiological category vice system category.

Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier MatrixFGt Loss of any two barriers AND Loss or Potential Loss of third bamer. 1.2,3,4 FS1 Loss or Potential Loss of ANY two bamers. 1.2.3.4 FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1.2.3,4FC -Fuel C lad RC -Reactor Coolant System CT -Containment Lub-Category Loss Potential Loss Loss Potential Loss Loss Potential LossA. Operation of a standby charging(makeup) pump is required by EITHER ofA. An automatic or manual ECCS (SI) the following:

A actuation is required by EITHER of the a UNISOLABLE RCS leakageA. RCSlreactor vessel level less OR1. RCS or SG None than (site-specific level). following:

b. SG tube leakage.

A leaking or RUPTURED SG is NoneTube Leakage a. UNISOLABLE RCS leakage OR FAULTED outside of containment.

OR B. RCS cooldown rate greater thanb. SG tube RUPTURE.

(site specific pressurized thermalshock criteriallimits defined by sitespecific Indications)

A. Core exit thermocouple readingsgreater than (site specific A. 1. (site specific criteria for entry intoA. Core exit thermocouple temperature value) A. Inadequate RCS heat removal core cooling restoration procedure)

2. Inadequate readings greater than (site OR None capability via steam generatore as None ANDHeat Removal specific temperature value) B. Inadequate RCS heat removal indicated by (site specific Indications).
2. Functional Restoration Procedures capability via steam generators not effective in < 15 minutes.as indicated by (site specificindications).

A, Containment radiation monitorreading greater than (site specific3 RCS Activity/

value) A. Containment radiation monitor A. Containment radiation monitor readingContainment OR None reading greater than (site specific value) None None greater than (she specific value)Radiation B, (Site specific indications that reactorcoolant activity is greater than 300uCi/gm dose equivalent 1-131).A.Containment isolation is required AND A. Containment pressure greater than (siteEITHER of the following:

specific value)1. Containment integrity has been ORlost based on Emergency Director B. Explosive mixture exists insidejudgement.

containment.

4.Containment OR ORIntegrity or None None None NoneBypass 2. UNISOLABLE pathway from C. 1. Containment pressure greater thancontainment to the environment (site specific value)exists. ANDOR 2. Less than one full train of (siteB Indication of RCS leakage outside of specific equipment) is operating containment per design for _15 minutes.A, Any Condition in the opinion of the A. Any condition in the opinion of the A. ANY Condition in the opinion ot the A. Any Condition in the opieonof the A. Any Condition in the opinion of the A. Any Conditon in the opinion of the Emergency

5. Emergency n Emergency Director that indicates Loss mergecy Director that indicates Potential Emergeecy Director thar indicates Lose at Emergency Director tsar indicates Potential Emergency Director tsar idicates Loss ot the Director that indicates Potential Loss of theDirector Judgment of the Fuel Clad Barier. Loss of the Fuel Clad Barner. the RCS Barmer. Loss of the RCS Bamer. Containment Barrier.

Containment Barrer.Page II of 66 Proposed Fission Product Barrier MatdxFG1 Loss of any Iwo banriors AND Loss or Potential Loss of third barrier.

FBI Loss or Potential Loss of ANY two barrers.

[fE [ FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS OEMi~iFC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category, Loss Potential Loss Loss Potential Loss Loss Potential Loss2. UNISOLABLE RCS leakage >159gpm.1. RCITS hot leg instruments indicate

1. Automatic or manual ESAS adtuation is OR0 inches after lowering trend, required by EITHER of the following:

AND a. UNISOLABLE RCS leakage 3. HPI-PDRV Cooling in elfect. l e >b LRCS or Sg None 2. In-core thermocouples are unavailable.

OR OR 2. SG is FAULTED outside of containment.

NoneTube Leakage AND b. Steam Generator tube 4. a. RCS Pressure a 2450 psig.3. ALL RCP's are secured.

RUPTURE.ANDb. RCS Pressure not lowering1. T_ a _ 1800iF.2. > 25"F Superheat AND2. Inadequate

1. T > 14001F OR None None 2. EOP Restoration procedures notHeat Removal 3. HPF-PORV Cooling in effect. HPI-PORV Cooling in effect. effective ine< 1 minutes.1. Containment radiation monitor (RM-G-22 or RM-G-23) reading > 1.95E+033. Containment R/hr. Containment radiation monitor (RM-G-22 or Containment radiation monitor (RM*G-22 orRadiation

/ RCS OR None RM-G-23) reading > 25 Rlhr. None None RM-G-23) reading > 4.40E+03 R/hr oAdivity 2. Coolant activity

> 300uCi/gm DoseEquivalent 1-1313. Reactor Building Pressure

> 55 psig1. Containment isolation is required and and rising.EITHER of the following:

ORa. UNPLANNED lowering in 4. Hydrogen Concentration incontainment pressure or rise in Containment a 4%.radiation monitor readings ORoutside of containment in the 5. a. Reactor Budding pressureEmergency Directors judgment 30 psigindicate a loss of containment

4. Containment None None None None integrity.

ANDIntegnty or Bypass OR b. Reactor Building Emergency

b. UNIODLABLE pathway frow cooling is less than ANY one of thecontainment to the f cniosenvironment exists.OR SPRAY COOLERS2. Indication of RCS leakage outside of 2 0containment 0 31 15. Emergency
1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of theDirector Judgment Emergency Director that indicates Emergency Director that indicates Emergency Director that indicates Emergency Director that indicates Emergency Diredtor that indicates Potential Loss el te Containment Loss of the Fuel Clad Bater. Potential Loss of the Fuel Clad Barrier.

Loss of the RCS Baoer. Potential Loss of the RCS Bater. Loss of the Containment Baoier. Boatrer.Page 12 of 66 NEI 99-01 Rev 6 Proposed EAL Justification F~l[F, jJ- No Change [j Difference Li Deviation Category:

Fuel Clad Barrier Category:

Fuel Clad BarrierRCS or SG tube leakage RCS or SG tube leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot Shutdown 1,2, 3,4Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential LossA. RCS/reactor vessel level less than (site-specific level). 1. RCITS hot leg instruments indicate 0 inches after lowering trend.AND2. In-core thermocouples are unavailable.

AND3. ALL RCP's are secured.Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC2 Category:

Fuel Clad BarrierC2 No Change D Difference Deviation Inadequate Heat Removal RCS Activity

1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) Potential Loss #3, The initiation of HPI -PORV cooling creates a controlled Power Operation,
Startup, Hot Standby, Hot Shutdown 1,2, 3, 4 opening of the RCS to the RB by an open PORV. This is indicative of the steamFission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

generators inability to remove heat from the RCS and represents a potential challenge to the FC barrier and is considered a potential loss.Loss LossA. Core exit thermocouple readings greater than (site-specific temperature value). 1. Trad > 1400°FPotential Loss Potential LossA. Core exit thermocouple readings greater than (site-specific temperature value). 2. > 25°F Superheat OR ORB. Inadequate RCS heat removal capability via steam generators as indicated by 3. HPI-PORV Cooling in effect.(site-specific indications).

Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC3 Category:

Fuel Clad Barrier 'C3 E No Change Difference Deviation Containment Radiation

/ RCS Activity Containment Radiation

/ RCS Activity

1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot Shutdown 1,2.3. 4Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss LossA. Containment radiation monitor reading greater than (site-specific value). 1. Containment radiation monitor (RM-G-22 or RM-G-23) readingOR > 1.95E+03 R/hr.ORB. (Site-specific indications that reactor coolant activity is greater than 300 iC[igm 2. Coolant activityR>

300uCigm Dose Equivalent 1-131dose equivalent 1-131).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC6 Category:

Fuel Clad Barrier FC5 No Change Differne Deviation Emergency Director Judgment Emergency Director JudgmentOperating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup.

Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Fuel Clad Barrier.

the Fuel Clad Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.

Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC1 C1 [--]No Change [---- Difference Deviation Category:

Reactor Coolant System Barrier Category:

Reactor Coolant System BarrierRCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) Potential loss threshold
  1. 2 is based on the inability to maintain normal liquidPower Operation,
Startup, Hot Standby, Hot Shutdown 1,2, 3.4 inventory within the RCS by normal operation of the Make Up System, when oneFission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Make Up Pump is discharging to the charging header. The need for a secondMake Up Pump or the use of the high capacity makeup rate would be indicative ofLoss Loss a substantial RCS leak. 120 gpm is the nominal capacity of each Make Up Pump.However, 150 gpm (high makeup flow alarm setpoint) was selected because it isA. An automatic or manual ECCS (SI) actuation is required by EITHER of the 1. Automatic or manual ESAS actuation is required by EITHER of the following:

more easily recognized by the operator which will result in a more timelyfollowing:

a. UNISOLABLE RCS leakage declaration than performing a calculation.
1. UNISOLABLE RCS leakage OROR b. Steam Generator tube RUPTURE.
2) Potential Loss #3, The initiation of HPI -PORV cooling creates a controlled
2. SG tube RUPTURE.

Potential Loss opening of the RCS to the RB by an open PORV. The opening of the RCS and thesPotential Loss pressure control mode through throttling of the HPI and or MU valves represents a2. UNISOLABLE RCS leakage > 150gpm. potential challenge to the RCS barrier and is considered a potential loss.A. Operation of a standby charging (makeup) pump is required by EITHER of the ORfollowing:

3) Potential Loss #4, The pressurizer code safety valves will open between 24501. UNISOLABLE RCS leakage 3. HPI-PORV Cooling in effect. psig and 2510 psig(allowance for set pressure and Code Safety valveOR OR accumulation).

This is the design limit for the RCS and well within tested values(2750 psig). If the RCS heatup is able to keep the pressurizer code safety valves2. SG tube leakage.

4. a. RCS Pressure

> 2450 psig. open with pressure either increasing or cycling then the RCS shall be considered aOR AND potential breach.B. RCS cooldown rate greater than (site-specific pressurized thermal shockcriteria/limits defined by site-specific indications).

b. RCS Pressure not loweuing.
4) The proposed EAL provides the Operators with a clear and easily recognizable entry condition for this EAL without altering the intent of the EAL. The usage ofthe specified thresholds would ensure timely declaration should this event occur.TMI is using these conditions as entry into this EAL to mimic the concerns of thePotential Loss of RCS as shown in the Westinghouse CSFT monitoring forpressurized thermal shock (PTS) through the use of the RCS integrity red path.These are the same thresholds as what was approved in EArs based on NEI 99-01 Rev 5.Page 17 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC2 Category:

Reactor Coolant System BarrierRC2 No Change Difference Deviation Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) The initiation of HPI -PORV cooling creates a controlled opening of the RCS toPower Operation,
Startup, Hot Standby, Hot Shutdown 1,2,3,4 the RB by an open PORVW The opening of the RCS and the pressure control modeFission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

through throttling of the HPI and or MU valves represents a potential challenge tothe RCS barrier and is considered a potential loss.Potential Loss Potential LossA. Inadequate RCS heat removal capability via steam generators as indicated by HPI-PORV Cooling in effect.(site-specific indications).

Page 18 of 66 NEI 99-01 Rev 6Proposed EALJustification 4 i-RC3Category:

Reactor Coolant System BarrierContainment Radiation I RCS ActivityOperating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:

LossA. Containment radiation monitor reading greater than (site-specific value).RC3Category:

Reactor Coolant System BarrierRCS Leak RateOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LossContainment radiation monitor (RM-G-22 or RM-G-23) reading > 25 RJhr.E No Change I Difference 1 Deviation

1) Listed site-specific systems and threshold values to ensure timely classification.

Page 19 of 66 NEt 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC6 Category:

Reactor Coolant System Barrier RC5 No Change Difference Deviation Emergency Director Judgment Emergency director JudgmentOperating Mode Applicability:

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot Shutdown 1,23,34Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss ofthe RCS Barrier.

the RCS Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT1 Category:

Containment Barrier No Change Diffe ce Deviation RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss LossA. A leaking or RUPTURED SG is FAULTED outside of containment.

1. SG tube leakage > 150gpmAND2. SG is FAULTED outside of containment.

Page 21 of66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6Proposed EALJustification i i +CT2Category:

Containment BarrierInadequate Heat RemovalOperating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:

Potential LossA. 1. (Site-specific criteria for entry into core cooling restoration procedure)

AND2. Restoration procedure not effective within 15 minutes.CT2Category:

Containment BarrierInadequate Heat RemovalOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

Potential Loss1. T.,ý > 1 800°F.AND2. EOP Restoration procedures not effective in < 15 minutes.I--E No Change D: Difference 1:1 Deviation

1) Listed site-specific threshold values to ensure timely classification.

Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT3 Category:

Containment Barrier CT3 [ No Change Differce Deviation Containment Radiation

/ RCS Activity Containment Radiation

/ RCS Activity

1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential LossA. Containment radiation monitor reading greater than (site-specific value). Containment radiation monitor (RM-G-22 or RM-G-23) reading > 4.40E+03 R/hr.Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CT4 CT4 -NChne Dfeee DeatoCategory:

Containment Barrier Category:

Containment Barrier C No Change Difference Deviation Containment Integrity or Bypass Containment Integrity or Bypass 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss LossA. Containment isolation is required

1. Containment isolation is required and EITHER of the following:

AND a. UNPLANNED lowering in containment pressure or rise in radiation monitorreadings outside of containment in the Emergency Directors judgmentEITHER of the following:

indicate a loss of containment integrity.

1. Containment integrity has been lost based on Emergency Director ORjudgment.

OR b. UNISOLABLE pathway from containment to the environment exists.2. UNISOLABLE pathway from the containment to the environment exists. OROR 2. Indication of RCS leakage outside of containment B. Indications of RCS leakage outside of containment.

Potential LossPotential Loss 3. Reactor Building Pressure

> 55 psig and rising.ORA. Containment pressure greater than (site-specific value) 4. Hydrogen Concentration in Containment

> 4%.OR ORB. Explosive mixture exists inside containment

5. a. Reactor Building pressure

> 30 psigOR ANDC. 1. Containment pressure greater than (site-specific pressure setpoint)

b. Reactor Building Emergency cooling is less than ANY one of the following AND conditions:
2. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer. SPRAY COOLERS2 00 31 1Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT6 Category:

Containment BarriCerT5 No Change Difference Deviation Emergency director Judgment Emergency Director JudgmentOperating Mode Applicability:

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot Shutdown 1,2, 3, 4Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Containment Barrier.

the Containment Barnier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.

Loss of the Containment Barrier.Page 25 of 66 0NEI 99-01 Rev 6 1 Proposed EAL I Justification SG1Initiating Condition:

GENERAL EMERGENCY Prolonged loss of all offsite and all onsite AC power to emergency buses.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the General Emergency promptlyupon determining that (site-specific hours) has been exceeded, or willlikely be exceeded.
1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).ANDb. EITHER of the following:

" Restoration of at least one emergency bus in less than(site-specific hours) is not likely." (Site-specific indication of an inability to adequately remove heat from the core)MG1Initiating Condition:

Prolonged loss of all offsite and all onsite AC power to emergency buses.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. EITHER of the following:
a. Restoration of at least one Emergency 4KV bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.ORb. > 25°F superheat F- No Change Difference Deviation
1) Listed site specific equipment, site specific time based on station blackoutcoping analysis, and site specific indication to ensure timely classification.

Page 26 of 66 0NEt 99-01 Rev 6 fProposed EAL Justification ss1Initiating Condition:

SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.MS1Initiating Condition:

Loss of all offsite and onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. Loss of ALL ofasite AC Power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutesfrom the time of loss of both offsite and onsite AC powerNo Change 1-1 Difference FIDeviation
1) Listed site specific equipment to ensure timely classification.

Page 27 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA1Initiating Condition:

ALERTLoss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely be exceeded.
1. a. AC power capability to (site-specific emergency buses) is reduced to a.single power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.MAIInitiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. AC power capability to Emergency 4KV buses reduced to only one of thefollowing power sources for > 15 minutes.* Auxiliary Transformer 1A* Auxiliary Transformer 1B* Emergency Diesel Generator EG-Y-1A* Emergency Diesel Generator EG-Y-1B* SBO Diesel Generator EG-Y-4AND2. Any additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.M No Change FIDifference I] Deviation
1) Listed site specific equipment to ensure timely classification.

.1 IPage 28 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification SulInitiating Condition:

UNUSUAL EVENTLoss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.

Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15minutes or longerMUlInitiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

Loss of ALL offsite AC power capability to Emergency 4KV busses fora 15 minutes.I No Change FIDifference I Deviation

1) Listed site specific equipment to ensure timely classification.

Page 29 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SG8Initiating Condition:

GENERAL EMERGENCY Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

Power Operation.

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the General Emergency promptlyupon determining that 15 minutes has been exceeded, or will likely beexceeded.
1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.ANDIndicated voltage is less than (site-specific bus voltage value) on ALL(site-specific vital DC busses) for 15 minutes or longer.MG2Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer:Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Voltage is < 105 VDC on 125 VDC Distribution System 1A and lB.AND4. ALL AC and Vital DC power sources have been lost for >_15 minutes.D- No Change M Difference

-IDeviation

1) Listed site specific voltage and equipment to ensure timely classification.
2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare,Page 30 of 66 NEI 99-01 Rev 6 JProposed EAL Justification b$8MS2Initiating Condition:

SITE AREA EMERGENCY Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:

D No ChangeI Difference

] Deviation Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, orwill likely be exceeded.

Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DCbuses for 15 minutes or longer.Initiating Condition:

Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

Voltage is < 105 VDC on 125 VDC Distribution System 1A and lB for>15 minutes.1) Listed site specific voltage and equipment to ensure timely classification.

2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 31 of`66 NEI 99-01 Rev 6 1 Proposed EAL I Justification SS5Initiating Condition:

SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPVwater level [BWR]) or RCS heat removal.Operating Mode Applicability:

Power Operation Example Emergency Action Levels:1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown thereactor.ANDb. All manual actions to shutdown the reactor have been unsuccessful.

ANDC. EITHER of the following conditions exist:1. (Site-specific indication of an inability to adequately remove heat from the core)OR2. (Site-specific indication of an inability to adequately remove heat from the RCS)MS3Initiating Condition:

Inability to shutdown the reactor causing a challenge to core cooling or RCS heatremoval.Operating Mode Applicability:

1.2Emergency Action Levels (EAL):1. Automatic or Manual Trip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. ALL manual actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 5%.AND3. EITHER of the following conditions exist:a. Tad > 1400°F.ORb. HPI-PORV Cooling in effect.D- No Change F Difference

[IDeviation

1) Listed site specific indications to ensure timely classification.
2) Mode 2 included in operating mode applicability as per developer notes.3) The initiation of HPI -PORV cooling creates a controlled opening of the RCS tothe RB by an open PORV. This is indicative of the steam generators inability toremove heat from the RCS.Page 32 of 66 NEI 99-01 Rev 6Prpoe _AJustification NEt 99-01 Rev B Proposed EAL Justification iSA5Initiating Condition:

ALERTAutomatic or manual (trip [PWRJ / scram [BWRJ) fails to shutdown the reactor, andsubsequent manual actions taken at the reactor control consoles are notsuccessful in thutting down the reactor.Operating Mode Applicability:

Power Operation Example Emergency Action Levels:Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown thereactor.ANDb. Manual action taken at the reactor control consoles are notsuccessful in shutting down the reactor.MA3Initiating Condition:

Automatic or manual trip fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting downthe reactor.Operating Mode Applicability:

1,2Emergency Action Levels (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.

1. Automatic Trip did not shutdown the reactor as indicated by Reactor Power> 5%.AND2. Manual actions taken at the Console Center are not successful in shuttingdown the reactor as indicated by Reactor Power > 5%.F-1 No Change FIDifference 1 Deviation
1) Listed site specific indications to ensure timely classification.
2) Mode 2 included in operating mode applicability as per developer notes.Page 33 of 66 NEI 90-01 Rev 6 [Proposed EAL Justification SUSInitiating Condition:

UNUSUAL EVENTAutomatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: (1 or 2)Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.

1. a. An automatic (trip [PWR] / scram [BWRI) did not shutdown thereactor.ANDb. A subsequent manual action taken at the reactor control consoles issuccessful in shutting down the reactor.2. a. A manual trip ([PWR] / scram [BWR]) did not shutdown the reactor.ANDb. EITHER of the following:
1. A subsequent manual action taken at the reactor control consolesis successful in shutting down the reactor.OR2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.MU3Initiating Condition:

Automatic or manual trip fails to shutdown the reactor.Operating Mode Applicability:

F- No Change I-1 Difference FIDeviation

1) Listed site specific indications to ensure timely classification.
2) Mode 2 included in operating mode applicability as per developer notes.1,2Emergency Action Levels (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
1. a. Automatic Trip did not shutdown the reactor as indicated by ReactorPower > 5%.ANDb. Subsequent manual action taken at the Console Center is successful inshutting down the reactor.OR2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power> 5%.ANDb. Subsequent automatic Trip is successful in shutting down the reactor.Page 34 of 66 NEI 99-01 Rev 6SA2Initiating Condition:

ALERTUNPLANNED lost, of Control Room indications for 15 minutes or longer with a significant transient in progress.

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upon determining that15 minutes has been exceeded, or will likely be exceeded.
1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below]I BWR parameter list] I PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit Temperature Suppression Pool Level Levels in at least (site specific number)steam generators Steam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowANDb. Any of the following transient events in progress.
  • Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical loadReactor Scram [BWR] / trp [PWR]* ECCS (SI) actuation
  • Thermal power oscillations greater than 10% [BWR]Proposed EALJustification

-F +MA4Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.

Operating Mode Applicability:

1.2,23,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. a An UNPLANNED event results in the inability to monitor ANY Table M1parameters from within the Control Room for > 16 minutes.Table M1 Control Room Parameters
  • Reactor Power* PZR Level* RCS Pressure* In Core/Core Exit Temperature
  • Level in at least one OTSG.* OTSG Emergency Feed Water FlowANDb. ANY Table M2 transient in progress.

Table M2 Significant Transients

  • Automatic Turbine Runback >25% thermal reactor power* Electrical Load Rejection

>26% full electrical load* Reactor Trip* ESAS Actuation

  • Thermal Power oscillations

> 10%H No Change FIDifference

-IDeviation

1) Listed site specific number of steam generators to ensure timely classification.

Page 35 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SU2Initiating Condition:

UNUSUAL EVENTUNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.

An UNPLANNED event results in the inability to monitor one or more of thefollowing parameters from within the Control Room for 15 minutes or longer.[see table below][ BWR parameter list] [PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrmary Containment Pressure In Core/Core Exit Temperature nPool Level Levels in at least (site specificSuppression Pnumber) steam generators Steam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowMU4Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters

" Reactor Power" PZR Level* RCS Pressure* In Core/Core Exit Temperature

" Level in at least one OTSG." OTSG Emergency Feed Water FlowF No Change 1 Difference FI Deviation

1) Listed site specific number of steam generators to ensure timely classification.

Page 36 of 66 0NEI 99-01 Rev 6 Proposed EAL j Justification SA9Initiating Condition:

ALERTHazardous event affecting a SAFETY SYSTEM needed for the currentoperating mode.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)
  • Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION
  • (site-specific hazards)* Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:
1. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEM needed for thecurrent operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure needed for the current operating mode.MA5Initiating Condition:

ALERTHazardous event affecting a SAFETY SYSTEM required for the currentoperating mode.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

  • Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION
  • Other events with similar hazard characteristics asdetermined by the Shift ManagerAND2. EITHER of the following:
a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by Technical Specifications for the current operating mode.F] No Change M Difference

[Deviation

1) No additional site specific hazards noted2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators andminimize confusion.

Page 37 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU4Initiating Condition:

UNUSUAL EVENTRCS leakage for 15 minutes or longer.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.
1. RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer.2. RCS identified leakage greater than (site-specific value) for 15 minutes orlonger3. Leakage from the RCS to a location outside containment greater than 25gpm for 15 minutes or longerMU6Initiating Condition:

RCS leakage for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15minutesOR2. RCS identified leakage >25 gpm for > 15 minutesOR3. Leakage from the RCS to a location outside containment

>28 gpm for> 15 minutesNo Change 1 Difference FIDeviation

1) Listed site specific values to ensure timely classification.

Page 38 of 66 NEI 99-01 Rev 6 ] Proposed EAL I Justification SU6Initiating Condition:

UNUSUAL EVENTLoss of all onsite or offsite communications capabilities Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)MU7Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1,2,3,4Emergency Action Levels (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting theability to perform routine operations.

OR2. Loss of ALL Table M3 Offsite communication capability affecting theability to perform offsite notifications.

OR3. Loss of ALL Table M3 NRC communication capability affecting the abilityto perform NRC notifications.

Table M3 Communications Capability System Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X XF No Change FIDifference

-IDeviation

1) Listed site specific communication methods to ensure timely classification.

Page 39 of 66 NEI 99-01 Rev 6 1 Proposed EAL [Justification SU7Initiating Condition:

UNUSUAL EVENTFailure to isolate containment or loss of containment pressure control.

[PWR]Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2)1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ALL required penetrations are not closed within 15 minutes of theactuation signal.2. a. Containment pressure greater than (site-specific pressure).

ANDb. Less than one full train of (site-specific system or equipment) isoperating per design for 15 minutes or longer.MU8Initiating Condition:

Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:

1,2.3,4Emergency Action Levels (EAL):1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ANY required penetration remains open > 15 minutes of the actuation signal.OR2. a. Reactor Building pressure

> 30 psigANDb. Reactor Building Emergency cooling is less than ANY one of thefollowing conditions for > 15 minutes:SPRAY COOLERS2 00 31 1FH No Change 1 -] Difference FIDeviation

1) Listed site specific indications to ensure timely classification.
2) Reworded EAL 1.b to be a positive statement Page 40 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA2Initiating Condition:

ALERTLoss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:

Cold Shutdown, Refueling, DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.CA1Initiating Condition:

Loss of all offsite and onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:

5,6, DEmergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4SBO Diesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutesfrom the time of loss of both offsite and onsite AC power.E No Change 1 Difference 1 Deviation
1) Listed site specific equipment to ensure timely classification.

Page 41 of 66 NEt 99-01 Rev' S Proposed EAL Justification NEI 99-01 Rev6Proposed EALJustification

+ -tCU2Initiating Condition:

UNUSUAL EVENTLoss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling.

DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely be exceeded.

1. a. AC power capability to (site-specific emergency buses) is reduced to asingle power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.CulInitiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes orlonger.Operating Mode Applicability:

5.6,0Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. AC power capability to Emergency 4KV buses reduced to only one of thefollowing power sources for > 15 minutes." Auxiliary Transformer 1A" Auxiliary Transformer 1 B" Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1B" SBO Diesel Generator EG-Y-4AND2. ANY additional single power source failure will result in a loss of ALL ACpower to SAFETY SYSTEMS.E No Change 1 Difference 1 Deviation
1) Listed site specific equipment to ensure timely classification.

Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA6Initiating Condition

-ALERTHazardous event affecting SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)

  • Internal or external flooding event* High winds or tomado strike* FIRE" EXPLOSION

" (site-specific hazards)* Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:

1. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMneeded for the current operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure needed for the currentoperating mode.CA2Initiating Condition:

Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:

5,6Emergency Action Levels (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

  • Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION
  • Other events with similar hazard characteristics asdetermined by the Shift ManagerAND2. EITHER of the following:
a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by Technical Specifications for the current operating mode.H No Change E Difference Deviation
1) No additional site specific hazards noted2) Changed the word "needed" to "required" in the IC and "required byTechnical Specification" in the EAL to be consistent with terminology used byoperators and minimize confusion.

Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU4Initiating Condition:

UNUSUAL EVENTLoss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.

Indicated voltage is less than (site-specific bus voltage value) on required Vital DCbuses for 15 minutes or longer.CU3Initiating Condition:

Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:

5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

Voltage is < 105 VOC on required 125 VDC Distribution System 1A and 1B fora 15 minutes.D- No Change[-q Difference

[I] Deviation

1) Listed site specific voltage and equipment to ensure timely classification.
2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 44 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU5Initiating Condition:

UNUSUAL EVENTLoss of all ornsite or offsite communications capabilities Operating Mode Applicability:

Cold Shutdown, Refueling, DefuledExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)CU4Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

5,6, DEmergency Action Levels (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting theability to perform routine operations.

OR2. Loss of ALL Table C1 Offsite communication capability affecting theability to perform offsite notifications.

OR3. Loss of ALL Table C1 NRC communication capability affecting theability to perform NRC notifications.

Table C1 Communications Ca pabilitySystem Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X XE No Change 1 Difference 1 Deviation

1) Listed site specific communications methods to ensure timely classification Page 45 of 66 NEI 99-01 Rev 6 Proposed EAL ] Justification CA3Initiating Condition:

ALERTInability to maintain the plant in cold shutdown.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upondetermining that the applicable has been exceeded, or will likely beexceeded.

1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater thanthe duration specified in the following table.2. UNPLANNED RCS pressure increase greater than (site-specific pressurereading).

(This EAL does not apply during water-solid plant conditions.

[PWR])CA5Initiating Condition:

Inability to maintain plant in cold shutdown.

Operating Mode Applicability:

5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. UNPLANNED rise in RCS temperature

> 2000F due to loss of decayheat removal for > Table C2 duration.

OR2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal.

(This EAL does not apply duringwater- solid plant conditions.)

1:1 No ChangeEl Difference

[--] Deviation

1) Listed site specific Technical Specification cold shutdown temperature limit toensure timely classification.
2) Listed site specific pressure reading to enhance timely classification.
3) Added wording relating the temp and press rise to a loss of decay heat removalcapability as per the developer notes for PWR'sTable: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up DurationStatusIntact (but notRCS Reduced Not Applicable 60 minutes*Inventory

[PWR])Not Intact (or at Established 20 minutes*reduced inventory

-[PWRJ) Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame andRCS temperature is being reduced, the EAL is not applicable.

Thht~ C2 RC~ Weat-,~m O.,rattnn Threchnids RCS Status Containment Closure Heat-up DurationStatusIntact Not Applicable 60 minutes*Not IntactEstablished 20 minutes*ORReducedInventory Not Established 0 minutesIf an RCS heat removal system is in operation within this timeframe and RCS temperature is being reduced, then EAL #1 is notapolicable.

Page 46 of 66 NPI 99-01 Rev 6 Proposed EAL Justification CU3Initiating Condition:

UNUSUAL EVENTUNPLANNED increase in RCS temperature.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 15 minutes time has been exceeded, or will likelybe exceeded,

1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vessel/RCS

[PWR] or RPV[BWRI) level indication for 15 minutes or longer.CU5Initiating Condition:

UNPLANNED rise in RCS temperature.

Operating Mode Applicability:

5,6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.

1. UNPLANNED rise in RCS temperature

> 200*F due to loss of decayheat removal.OR2. Loss of the following for > 15 minutes.* ALL RCS temperature indications AND* ALL RCS level indications D No Change E Difference FIDeviation

1) Listed site specific Technical Specification cold shutdown temperature limitto ensure timely classification.
2) Changed the word increase to rise in the initiating condition to be consistent with operations language and training.

Page 47 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification CG1Initiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS IPWR] or RPV [BWRI) inventory affecting fuel cladintegrity with containment challenged.

Operating Mode Applicability:

Cold Shutdown.

Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 30 minutes time has been exceeded, or will likelybe exceeded.

1. a. (Reactor vessel/RCS

[PWRJ or RPV [BWRJ) vessel level less than (site-specific level) for 30 minutes or longer.ANDb. ANY indication from the Containment Challenge Table2. a.. (Reactor vessel/RCS

[PWR] or RPV [BWR]) vessel level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:

  • (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication

[PWRJ* UNPLANNED increase in (site-specific sump and/or tank levels) ofsufficient magnitude to indicate core uncovery* (Other site-specific indications)

ANDc. ANY indication from the Containment Challenge Table).CG6Initiating Condition:

Loss of reactor vessel / RCS inventory affecting fuel clad integrity withcontainment challenged.

Operating Mode Applicability:

5,6H No Change E Difference 1 Deviation

1) EAL 1 a not included as per guidance in developer notes since top of activefuel is below level indication lowest value.2) Listed site specific radiation monitors to ensure timely classification
3) Listed site specific sumps and tanks to ensure timely classification
4) Listed Explosive mixture in the Containment Challenge Table to ensuretimely classification
5) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelyexceeded.
1. Reactor Vessel / RCS level unknown for >30 minutes.AND2. Core uncovery is indicated by ANY of the following:
  • Table C3 indications of a sufficient magnitude to indicate coreuncoveryOR* Erratic Source Range Neutron Monitor indication.

OR* Radiation Monitor RM-G-6 or RM-G-7 reading > 3 R/hr.AND3. ANY Containment Challenge Indication (Table C4)beTable C3 Indications of RCS Leakage* UNPLANNED Reactor Building Sump level rise** UNPLANNED Auxiliary Bldg Sump level rise'* UNPLANNED BWST level rise'* UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss.Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Table: Containment Challenge Table" CONTAINMENT CLOSURE not established*

  • (Explosive mixture) exists inside containment
  • UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWRI'if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.

Table C4 Containment Challenge Indications

" Hydrogen Concentration in Containment

> 4%* UNPLANNED rise in containment pressure" CONTAINMENT CLOSURE not established'

'if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to aGeneral Emergency is not required.

Page 48 of 66 NEI 99-01 Rev 6 1 Proposed EAL ] Justification CS1Initiating Condition:

SITE AREA EMERGENCY Loss of (reactor vesselIRCS

[PWR] or RPV [BWR]) inventory affecting coredecay heat removal capability.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 30 minutes time has been exceeded, or will likelybe exceeded.

1. a. CONTAINMENT CLOSURE not established.

ANDb. (Reactor vessel/RCS

[PWR) or RPV [BWR]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.

ANDb. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:

  • (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication

[PWR]* UNPLANNED increase in (site-specific sump and/or tanklevels) of sufficient magnitude to indicate core uncovery* (Other site-specific indications)

CS6Initiating Condition:

Loss of reactor vessel / RCS inventory affecting core decay heat removalcapabilities.

Operating Mode Applicability:

5,6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.

1. Reactor vessel level unknown for >30 minutes.AND2. Core uncovery is indicated by any of the following:
  • Table C3 indications of a sufficient magnitude to indicate coreuncoveryOR* Erratic Source Range Neutron Monitor indication.

OR* Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED Reactor Building Sump level rise** UNPLANNED Ausliary Bldg. Sump level rise'* UNPLANNED BWST level rise'* UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss'Rise in level is attributed to a loss of reactor vesselIRCS inventory.

[ No Change E Difference 1 Deviation

1) EAL 1 not included as per guidance in developer notes since 6" belowbottom ID of RCS loop is below level indication lowest value.2) EAL 2 not included as per guidance in developer notes since top of activefuel is below level indication lowest value,.3) Listed site specific radiation monitors to ensure timely classification
4) Listed site specific sumps and tanks to ensure timely classification
5) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 49 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationInitiating Condition:

ALERTLoss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 15 minutes time has been exceeded, or will likelybe exceeded.

1. Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory asindicated by level less than (site-specific level).2. a. (Reactor vessel/RCS

[PWRI or RPV [BWR]) level cannot bemonitored for 15 minutes or longerANDb. UNPLANNED increase in (site-specific sump and/or tank) levels dueto a loss of (reactor vessel/RCS

[PWR] or RPV [BWRI) inventory.

CABInitiating Condition:

Loss of reactor vessel / RCS inventory Operating Mode Applicability:

5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.

1. Loss of Reactor Vessel / RCS inventory as indicated by RCS level< 0 inches on Draindown Level indicator.

OR2. a. Reactor vessel / RCS level unknown for > 15 minutes.ANDb. Loss of reactor vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage* UNPLANNED Reactor Building Sump level rise** UNPLANNED AuJliary Bldg. Sump level rise*UNPLANNED BWST level rise** UNPLANNED RCDT level rise'* UNPLANNED rise in RCS makeup* Observation of leakage or inventory lossRise in level is attributed to a loss of reactor vessel/RCS inventory.

D No Change I Difference L-- Deviation

1) Listed site specific levels to ensure timely classification.
2) Listed site specific sumps and tanks to ensure timely classification.
3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 50 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Cu1Initiating Condition:

UNUSUAL EVENTUNPLANNED loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory for15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.

1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS

[PWR] or RPV [BWR]) level less than a required lower limit for 15minutes or longer.2. a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot bemonitored.

ANDb. UNPLANNED increase in (site-specific sump and/or tank) levels.CU6Initiating Condition:

UNPLANNED loss of reactor vessel / RCS inventory for 15 minutes or longer.Operating Mode Applicability:

5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. UNPLANNED loss of reactor coolant results in the inability to restoreand maintain reactor vessel / RCS level to> procedurally established lower limit for >_15 minutes.OR2. a. Reactor vessel / RCS level unknown.ANDb. Loss of reactor vessel / RCS inventory per Table C3 indications.

El No Change I Difference FIDeviation

1) Described "a required lower limit" as a procedurally established lower limit,and listed site specific sumps and tanks to ensure timely classification.
2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table C3 Indications of RCS Leakage* UNPLANNED Reactor Building Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise"* UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakaoe or inventory loss*Rise in level is attrbuted to a loss of reactor vessel/RCS inventory.

Page 51 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG1HG1Initiating Condition:

GENERAL EMERGENCY HOSTILE ACTION resulting in loss of physical control of the facility.

Operating Mode Applicability:

AJlExample Emergency Action Levels:1. a. A HOSTILE ACTION is occurring or has occurred within thePROTECTED AREA as reported by the (site-specific security shiftsupervision).

ANDb. EITHER of the following:

1. ANY of the following safety functions cannot be controlled ormaintained.

Reactivity controlCore cooling [PWR] I RPV water level [BWRJ* RCS heat removalOR2. Damage to spent fuel has occurred or is IMMINENTInitiating Condition:

HOSTILE ACTION resulting in loss of physical control of the facility.

Operating Mode Applicability:

1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.

ORb. Damage to spent fuel has occurred or is IMMINENTD-- No Change F Difference Deviation

1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for atimely classification.

Table H1 Safety Functions

" Reactivity Control(ability to shut down the reactor and keep it shutdown)

" Core Cooling (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)Page 52 of 66 0NEI 99-01 Rev 6 Proposed EAL I Justification HS1HSIInitiating Condition:

SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

Initiating Condition:

HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

E No Change FIDifference

[- Deviation

1) List site security shift supervision as Security Force.AllExample Emergency Action Levels:A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the (site-security shift supervision).

1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Page 53 of 66 NEI 99-01 Rev 6 J Proposed EAL Justification HA1Initiating Condition:

ALERTHOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attackthreat within 30 minutes.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2)1 A HOSTILE ACTION is occurring or has occurred within the OWNERCONTROLLED AREA as reported by the (site-specific security shiftsupervision).

2. A validated notification from NRC of an aircraft attack threat within 30minutes of the site.HA1Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airbome attackthreat within 30 minutes.Operating Mode Applicability:

1,2, 3,4,5, 6, DEmergency Action Levels (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutesfrom the site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring orhas occurred within the OWNER CONTROLED AREA.F-x No Change FIDifference F Deviation 1)Lisl site security shift supervision as Security Force.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENTConfirmed SECURITY CONDITION or threat.Operating Mode Applicability:

HUIAJIExample Emergency Action Levels: (1 or 2 or 3)1. A SECURITY CONDITION that does not involve a HOSTILE ACTION asreported by the (site-specific security shift supervision).

2. Notification of a credible security threat directed at the site.3. A validated notification from the NRC providing information of an aircraftthreat.HU1Initiating Condition:

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.

OR2. A validated notification from the NRC providing information of an aircraftthreat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.F No Change -IDifference LI1 Deviation

1) List site security shift supervision as Security Force.2) Further described credible security threat through listing a site specificprocedure.

Page 55 of 66 NEI 99-01 Rev 6 [Proposed EAL [Justification HS6Initiating Condition:

SITE AREA EMERGENCY Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 and 2)Note: The Emergency Director should declure the event promptly upon determining that (site-specific number of minutes) has been exceeded, or will likely beexceeded.

1. An event has resulted in plant control being transferred from the ControlRoom to (site-specific remote shutdown panels and local control stations).
2. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).

Reactivity control" Core cooling [PWRJ I RPV water level [BWR]RCS heat removalHS2Initiating Condition:

Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:

1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per OP-TM-EOP-020, Cooldown from Outsidethe Control Room.AND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table HI Safety Functions
  • Reactivity Control(ability to shut down the reactor and keep it shutdown)
  • Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)FD No Change M Difference 1 Deviation
1) EAL uses the site specific Control Room evacuation procedures toeffectively list all of the alternate locations, panels, and stations requested bythe developer notes. This would be the procedures the Control Room wouldenter should such an event occur, this allows for greater clarity as to whenthis EAL would apply than if each panel and station used in alternate shutdown were to be listed,2) Added descriptors to better explain each safety function and allow for atimely classification.
3) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlroom still manned, due to testing or equipment failure.Page 56 of 66 NEt 99-01 Rev 6 1 Proposed EAL IJustification HA6HA2Initiating Condition:

ALERTInitiating Condition:

D No Change[F Difference

--] Deviation Control Room evacuation resulting in transfer of plant control to alternate locations.

I Control Room evacuation resulting in transfer of plant control to alternate locations.

Operating Mode Applicability:

AllExample Emergency Action Levels:An event has resulted in plant control being transferred from the Control Room to(site-specific remote shutdown panels and local control stations).

Operating Mode Applicability:

1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):A Control Room evacuation has resulted in plant control being transferred fromthe Control Room to alternate locations per OP-TM-EOP-020, Cooldown fromOutside the Control Room.1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would enter should such anevent occur, this allows for greater clarity as to when this EAL would apply than ifeach panel and station used in alternate shutdown were to be listed,2) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlroom still manned, due to testing or equipment failure.Page 57 of 66 NEI 99-01 Rev 6 j Proposed EAL Justification HU4HU3Initiating Condition:

UNUSUAL EVENTFIRE potentially degrading the level of safely of the plant.Operating Mode Applicability:

Initiating Condition:

FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

1,2, 3,4, 5, 6, DLII No Change [-] Difference

[] Deviation

1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEMequipment to ensure timely classification.

AllExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Eventpromptly upon determining that the applicable time has beenexceeded, or will likely be exceeded.

1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:
  • Report from the field (i.e., visual observation)
  • Receipt of multiple (more than 1) fire alarms or indications
  • Field verification of a single fire alarmANDb. The FIRE is located within ANY of the following plant rooms or areas:(site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).ANDb. The FIRE is located within ANY of the following plant rooms or areas:(site-specific list of plant rooms or areas)ANDc. The existence of a FIRE is not verified within 30-minutes of alarm receipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plantProtected Areal PROTECTED AREA not extinguished within 60-minutes ofthe initial report, alarm or indication.
4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plantProtected Areal PROTECTED AREA that requires firefighting support by anoffsite fire response agency to extinguish.

Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. a. A FIRE in any Table H2 area is not extinguished in <15-minutes of ANYof the following FIRE detection indications:
  • Report from the field (i.e., visual observation)
  • Receipt of multiple (more than 1) fire alarms or indications
  • Field verification of a single fire alarmOR2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no otherindications of a FIRE).ANDb. The existence of a FIRE is not verified in <30-minutes of alarm receipt.OR3. A FIRE within the plant PROTECTED AREA not extinguished in <60-minutes of the initial report, alarm or indication.

OR4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Table H2 Vital Areas* Reactor Building* Intake Building* Intermediate Building* Control Tower* Auxiliary and Fuel Handling Buildings

  • 1A and 1 B Diesel Generator Buildings
  • BWST* CSTPage 58 of 66 0NEI 99-01 Rev 6 [Proposed EAL ] Justification Initiating Condition:

UNUSUAL EVENTSeismic event greater than OBE levels.Operating Mode Applicability:

HU2AllExample Emergency Action Levels:Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:a. (site-specific indication that a seismic event met or exceeded OBE limits)HU4Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by seismicAlarms PRF-1-3 Operating Basis earthquake and PRF-1-2 Threshold SeismicCondition.No Change 1 Difference FIDeviation

1) Listed site specific indication to determining OBE limits have been met orexceeded to ensure timely classification.

Page 59 of 66 NEI W9-01 Rev 6 Proposed EAL [Justification HA5Initiating Condition:

ALERTGaseous release impeding access to equipment necessary for normal plantoperations, cooldown or shutdown.

Operating Mode Applicability:

AilExample Emergency Action Levels:Note: If the equipment in the listed room or area was already inoperable, or outof service, before the event occurred, then no emergency classification iswarranted.

1. a. Release of a toxic, corrosive, asphyxiant or flammable gas into anyof the following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)

ANDb. Entry into the room or area is prohibited or impeded.HA5Initiating Condition:

Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability:

1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note: If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification iswarranted.

I. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.No Change FIDifference FIDeviation

1) Listed plant specific rooms and areas with entry related mode applicability toensure timely classification.

Table H3Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*

Modes 4, 5, and 6Intermediate Building*

Modes 4, 5, and 6Auxiliary Building*

Modes 4, 5, and 6Fuel Handling Building*

Modes 4, 5, and 6*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededPage 60 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENTHazardous EventOperating Mode Applicability:

HU3AtlExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: EAL #3 does not apply to routine traffic impediments such as fog, snow.ice, or vehicle breakdowns or accidents.

I. A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require manualor automatic electrical isolation of a SAFETY SYSTEM component neededfor the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due toan offsite event involving hazardous materials (e.g., an offsite chemicalspill or toxic gas release).

4. A hazardous event that results in on-site conditions sufficient to prohibitthe plant staff from accessing the site via personal vehicles.
5. (Site-specific list of natural or technological hazard events)HU6Initiating Condition:

Hazardous EventOperating Mode Applicability:

1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice,or vehicle breakdowns or accidents.

1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to anoffsite event involving hazardous materials (e.g., an offsite chemical spill ortoxic gas release).

OR4. A hazardous event that results in on-site conditions sufficient to prohibit theplant staff from accessing the site via personal vehicles.

OR5. Abnormal river water level at the intake Pump and Screen House, as indicated by EITHER:a. > 300 ft. el. (high level)ORb. < 274 ft. el. (low level)F No Change F Difference FIDeviation

1) Included river water level as part of the site-specific list of natural ortechnological hazard events. The EAL values selected are the current ApprovedUE EAL values.2) Changed the word "needed" to "required by Technical Specifications" in the EALto be consistent with terminology used by operators and minimize confusion.

Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL [Justification HG8HG7Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

x-1 No Change FIDifference FIDeviation Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.

Operating Mode Applicability:

AllExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control ofthe facility.

Releases can be reasonably expected to exceed EPA Protective ActionGuideline exposure levels off-site for more than the immediate site area.Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.

Operating Mode Applicability:

1,2, 3,4.5, 6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control ofthe facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..Page 62 of 66 SNEI 99-01 Rev 6 1 Proposed EAL Justification HS8HS7Initiating Condition:

SITE AREA EMERGENCY Initiating Condition:

M No Change. FIDifference 1-- Deviation Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency.

Operating Mode Applicability:

AJIExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely majorfailures of plant functions needed for protection of the public or HOSTILE ACTIONthat results in intentional damage or malicious acts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are notexpected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.

Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency.

Operating Mode Applicability:

1,2,3,4,5,6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely majorfailures of plant functions needed for protection of the public or HOSTILE ACTIONthat results in intentional damage or malicious acts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are notexpected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.

Page 63 of 66 NEI 99-01 Rev 6 ] Proposed EAL j Justification HA6Initiating Condition:

ALERTInitiating Condition:

HA7H No Change U Difference 1 Deviation Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an Alert.Operating Mode Applicability:

AlUExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to siteequipment because of HOSTILE ACTION. Any releases are expected to belimited to small fractions of the EPA Protective Action Guideline exposure levels.Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an Alert.Operating Mode Applicability:

1, 2, 3, 4, 5, 6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to siteequipment because of HOSTILE ACTION. Any releases are expected to belimited to small fractions of the EPA Protective Action Guideline exposure levels.Page 64 of 66 NEI 99-01 Rev 6 Proposed EAL [Justification HU7Initiating Condition:

UNUSUAL EVENTOther conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:

AlIExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated.

No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systemsoccurs.HU7Initiating Condition:

Other conditions existing which in thejudgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:

1,2,3,4,5,6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated.

No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systemsoccurs.W-1 No Change 1 Difference FIDeviation Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL Justification E-HU1mInitiating Condition:

UNUSUAL EVENT [-j No Change [ Difference

[j Deviation Damage to a loaded cask CONFINEMENT BOUNDARY.

TMI Station does not have an ISFSI,Operating Mode Applicability:

AllExample Emergency Action Levels:Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specifictechnical specification allowable radiation level) on the surface of the spent fuelcask.Page 66 of 66 Tkrgm U11m lalonA Qfatinn AnndmvPI:Yslnn h,:l"AarTkra~ u;ia I@IavmI ~*a*ij~mi Auinww Fv~Ir~n FJm.rI~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARG1Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRfem TEDEor 5000 mRfem thyroid CDE.Operating Mode Applicability:

1,2,3, 4,5,6, DEmergency Action Level (EAL):Notes:e The Emergency Director should declare the Gonoral Emergency event promptly upondetermining that the applicable time has been exceeded, or will likely be exceeded.

e If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established.

If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.

  • The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.

(1) Reading on ANY Of the folWIG ng radiation monitor-s greater than the reading shownfor 15 minutes Or longer:(cito SPoific moniRtor list and threshold v:alues)1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment Using actual meteorology indicates doses at or beyond (site-.... ;f*c doco r..ec.. Point) the site boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidORMonth 20XXTMI 3-1EP-AA-1009 (Revision XX) hroa Uila hainnel qtntinn AnnoyI=ynlnn N.nlpar1 II I Mii I isand Vtsat I AnnII vl IIE inn NucleaIrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS r-:iJ -ReluS~ve rA,.ArU4A r.,%iy8+-

a.9 Q teFbeetts

/%1 .... I * ...'-- --II .... J ...... JL__ __---__ -aL_ _ aa r'/'#', l ,L _--A A .JA -- --!A .... L----Closed windew dese FaTes WeffieF MaR JWWU FAPVRF eXPeGleO W GGRIIRUe f9fP60rMAtesn OrIrr(jnr I I ia I II ; I Pfor one hour Of inhalation.

3. Field survey results at or beyond the site boundarv indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate

> 5000 mRem CDE Thyroid for60 minutes of inhalation.

Table R1 Effluent Monitor Thresholds Effluent Monitor General Emergency RM-G-25 (Cond Offqas) 9.53 E+06 mR/hrRM-A-8GH (Station Vent) 3.09 E+05 cpmRM-G-24 (RB Purge) 5.55 E+05 mR/hrRM-A-14 (ESF Vent) 6.66 E+02 uCi/ccBasis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases.

Releases of this magnitude willrequire implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1000 mR-em while the 5000 mR-em thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.larssjification based on effluent monitor readings assumos that a release path to thenVironm~ent is, established.

if the effluent flow past an effluont moniorF 06 known to havMonth 20XXTMI 3-2EP-AA-1 009 (Revision XX) hrom Uila lainnei Qtatinn AnnovFYAInn Thr~Mu. chani ~tatin Anny Fvinn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS stopped due to actioea to- ioel-ate the releaso path, then the offluent moni;tor reading is- nolongor valid for clascification purpococ.

Basis Reference(s):

1. NE 199-01 Rev 6, AG12. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island3. EP-AA-1 12-500 Emergency Environmental Monitoring
4. FSAR Section 11.4 Radiation Monitoring System5. EP-AA-1 10-200 Dose Assessment
6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XXTMI 3-3EP-AA-1009 (Revision XX)

Three Mile tIslnd Station Annex E~xelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARSlInitiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mR-em TEDEor 500 mRfem thyroid CDE.Operating Mode Applicability:

1,2,3,4,5,6, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the Site Aoa Emergency event promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.

e If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established.

If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.

e The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.

(1) Reading on ANY Of the folloWing radiation mon.itors greater than the reading shownfor 15 minute O or lenger:

moRnitor list and threshold values)(2) Doeo assessment using acatual mneteorology indicates, doses greater than 100nre~m TEDES or 50 mrom thyroid CDE at Or boyen d (cite-specific dose recepto(3) Field cur.'ey rocults indicate EITHER of the following at Or beyond (cite specificdoe receptor pGOit):" Closed window dose rates greater-than 100 mR/hr expected to continue for 60 m~inutes" Analyses of field sun~ey samples indieate thyfeid CDE greater-than 500 maemn for: onehour- of inhalationi.

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.ORMonth 20XXTMI 3-4EP-AA-1009 (Revision XX)

Throp RAila 1-cland Atntinn AnnpvN.nlpnrThre Mil l~IanrI~tetnn AnexExelon Nucl~earTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

2. Dose assessment usina actual meteoroloav indicates doses at or bevond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundarv indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for > 60 minutes.ORAnalyses of field survey samples indicate

> 500 mRem CDE Thyroid for 60minutes of inhalation.

Table R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency RM-G-25 (Cond Offgas) 9.53 E+05 mR/hrRM-A-8GH (Station Vent) 3.09 E+04 cpmRM-G-24 (RB Purge) 5.55 E+04 mR/hrRM-A-14 (ESF Vent) 6.66 E+01 uCi/ccBasis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases.

Releases of this magnitude areassociated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mR-em while the 500 mR-emthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.%*~!1!k!

L....J -- .EtI....L

.!J.-A AI A J --I-lG-asiairatcaion hased on crnuten Imon-Tior r*SoAuinu assumos ;Rna

  • a r eicase eatrn tov..Month 20XXTMI 3-5EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS the environmcnt is octablished.

if the cfflucnt flow past an effluent.mntri known tohave stopped due to actions to ilthe thoreease path, then the effluent monGitor readgis no longer valid for claesificatio pupoosEscalation of the emergency classification level would be via IC RAG1.Basis Reference(s):

1. NEI 99-01 Rev 6, AS12. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island3. EP-AA-1 12-500 Emergency Environmental Monitoring
4. FSAR Section 11.4 Radiation Monitoring System5. EP-AA-1 10-200 Dose Assessment
6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XXTMI 3-6EP-AA-1 009 (Revision XX)

ExAIon NuelAarThriat Mia Ihqanrd Station Annex ExeInn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA1Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRiemTEDE or 50 mRfem thyroid CDE.Operating Mode Applicability:

1,2,3, 4,5,6, DEmergency Action Level (EAL):Notes:9 The Emergency Director should declare the Alet-event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

  • If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established.

If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.

e The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.

for 15 m"inutes or longer:(site6 pecific moRntor list and threshold v.'alues)

(2) Dose assessment using actual metoorolOg';

indicates dosees greater than 10 mrcmTEDE or 50 mromn thyroid CDE at or beYOnd (site spocific dose recee9tor pEGinfl.l i *(3) Analysis of a liquid effluent sample indicates a concentration Or release rate thatwould result in dosces greater than 10 mrom~ TEDE Or 50 mromn thyroid CDE atobeyond (site-specific dose receptor point) for ono hour Of exposure-.

(4) Field su...ey results indicate EITHE.R o.f t.he following at or beyond (sit, .pecificdose receptor pint):* Closed window dose rates ereater-than L0 fo'hr exoeetd to eantinue fer 60 fmutes orlenger-.a ¶ Jl" * " ] a~~~ a-*"~ a~ '-*-U*" v..%= a*'" ar'~~ aafia + mrr at-Pr fa"= AW 41MJ4 LAAA. ARPvhour of inhalation.

j b- -Month 20XXTMI 3-7EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate

> 50 mRem CDEThyroid for 60 minutes of inhalation.

Table R1 Effluent Monitor Thresholds Effluent Monitor AlertRM-G-25 (Cond Offqas) 9.53 E+04 mR/hrRM-A-8GH (Station Vent) 3.09 E+03 cpmRM-G-24 (RB Purge) 5.55 E+03 mR/hrRM-A-14 (ESF Vent) 6.66 E+00 uCVccMonth 20XXTMI 3-8EP-AA-1 009 (Revision XX)

Thrgna MiIA lalanfi Qtafirnn AnnovIFwalnn N, AalarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual offsite doses greater than or equal to 1% of the EPA Protective Action Guides(PAGs). It includes both monitored and un-monitored releases.

Releases of thismagnitude represent an actual or potential substantial degradation of the level of safety ofthe plant as indicated by a radiological release that significantly exceeds regulatory limits(e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mRfem while the 50 mR-em thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classiffication based on effluent monefitonr re-adfings acsumos that a roleaso path tothe enViroAnment is established.

If tho effluent flow-past.

an Aeffiluent moenitor is known tohave stopped duo to acti;ons to isolato the release path, then the offluePnt mnonitor reRaing;s no Ilnger valid forclasif;cation purpoe s.7Escalation of the emergency classification level would be via IC RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, AA12. OP 1101-2.1 Radiation Monitoring System Setpoints
3. FSAR Section 11.4 Radiation Monitoring System4. OP-TM-MAP-CO101, Radiation Level HI5. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island6. EP-EAL-0616, Revision 0, Three Mile Island Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values7. EP-EAL-0622, Revision 0, Three Mile Island Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values for Waste Gas Decay TanksMonth 20XXTMI 3-9EP-AA-1 009 (Revision XX)

Tkrg%,A%

Uilg% lalonri Qfation AnnavI:valrnn Hnn-lmarTkr~ MiI~ I.IanrI Qt~tirui Ann~v Fv.Inn Muu~I.~ar B B 1 *W*BB *5* 5 tt*WU .rB. B. j,~ * * -,*TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARUMInitiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM (kste-speelfiG efflu.nt

.eloase controlling document) limits for 60 minutes or longer.Operating Mode Applicability:

1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the Unusual Event event promptly upondetermining that 60-minutesthe applicable time has been exceeded, or will likely beexceeded.

" If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established.

If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.

(1) Reading on ANY effluent radiation monitor than 22 timnes t-he- (site specificeffluent release oRntrolling d.,umont).

Imits for 60 minutes Or Ilnger(cite-specific monitor list and threshold values corresponding to 2 times theControlling I-Mits(2) Reading on ANY effluent radiation monitor greater than 2 times the alar m setpestablished by a current radioactiveity discharige permit for 60 minutes or longer.(3) Sample analysis for a gaseous Or liquid release indicateS

-a concentration orrelease rate greater than 2 times th (site-specfific effluent release controllig documnent) limnits for 60 minutes Or longer.1. Reading on any of the following effluent monitors

> 2 times alarm setpointestablished by a current radioactive release discharge Permit for 2:60 minutes.i. RM-L-6, Radwaste Discharge ii. RM-L-1 2, IWTS / IWFS Discharge iii. RM-A-7, Waste Gas Decay Tank Discharge iv. Discharge Permit specified monitorOR2. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60 minutes.ORMonth 20XXTMI 3-10EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS

3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual EventRM-G-25 (Cond Offoas) 1.09 E+03 mR/hrRM-A-8GH (Station Vent) 7.03 E+01 cpmRM-G-24 (RB Purge) 6.34 E+01 mR/hrRM-A-14 (ESE Vent) 7.60 E-02 uCi/ccBasis:This IC addresses a potential decrease in the level of safety of the plant as indicated by alow-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release).

It includes any gaseous or liquidradiological

release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release ofradioactive effluents to the environment.

Further, there are administrative controlsestablished to prevent unintentional
releases, and to control and monitor intentional releases.

The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.

C-larssific-attion based on effluent moenitor ro-ad-ings assumes that a rclease pathtthe enVrOFnment ir, established.

if the effluent flow p'tanefluent moni~tor is knownthave Mtopped duo to ac-tions to islthe- Ih 'eosah, then the effluent monitor road-ingsc no longer valid for clIiiaioGupss Releases should not be prorated or averaged.

For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.EAL #1 Basis:EAL-#2--

This EAL addresses radioactivity releases that cause effluent radiation monitorreadings to exceed 2 times the limit established by a radioactivity discharge permit. ThisEAL will typically be associated with planned batch releases from non-continuous releaseoathwavs (e.g.. radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges.

If adischarge is performed using a different flowpath or effluent monitor other than thoseMonth 20XXTMI 3-11EP-AA-1009 (Revision XX) hrgga Uffis lalzanA Qtatinn Anniovi=Yplnn NiJnlpnrThr~ MIle Iclenri ~t~atinn Annev Fv~Inn Niir~Ic&~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS listed (e.g., a portable or temporary effluent monitor),

then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 Basis:EAL-#1---This EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous erI-iquid-effluent pathways.

EAL #3 Basis:EAL--#3 -This EAL addresses uncontrolled gaseous or liquid releases that are detectedby sample analyses or environmental

surveys, particularly on unmonitored pathways(e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river watersystems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):
1. NEI 99-01 Rev 6, AU12. OP 1101-2.1 Radiation Monitoring System Setpoints
3. FSAR Section 11.4 Radiation Monitoring System4. Offsite Dose Calculation (ODCM)5. OP-TM-MAP-CO101, Radiation Level HI6. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile IslandMonth 20XXTMI 3-12EP-AA-1 009 (Revision XX)

Three Mile Island Station Annex Exelon NuclanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA2Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:

1,2,3, 4,5,6, DEmergency Action Level (EAL):(1) Uncovor';

Of irradiatcd fuel in the REFUELING P.ATHWIA.IY.

2. Damage to irradiaced fuel resulting in a release of radioacivity from the fuel asindicated by ANY of R2 Radiation Monitorr i(sito Spocific listiRg of radiation
monitors, and tho associated
roadings, s Rtpoints and/RB alarms)(3) LIwonng of spent fuel pool level to (sitee tu pific Level 2 value). [tqh whv3ichNOtefe1 -Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R2 Radiation Monitor reading >1000 mRemlhrTable R2____________

Radiation Monitors_____

RMS Area Monitored ModeRM-G-9 FHB3 Bridge Rad Monitor ALLRM-G-6 RB Auxiliary Bridge Rad Monitor 5.6RM-G-7 RB Main Bridge Rad Monitor 5.6Basis:REFUELING PATHWAY:

all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.Month 20XXTMI 3-13EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS IMMINENT:

The traiectory of events or conditions is such that an EAL will be met within arelatively short period of time regardless of mitigation or corrective actions.This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly_.,

or a -nifclant low..ring of ,.,atar le. , within the ,pent fuel pool (SeeDeveloper.

,te,). These events present radiological safety challenges to plantpersonnel and are precursors to a release of radioactivity to the environment.

As such,they represent an actual or potential substantial degradation of the level of safety of theplant.This IC applies to irradi-atteed fueel that is licensod for dr; storage up to the point tatho loaded storage cask is soaled. Once sealed, damage to a leaded cask causing lescof the CONFINEMENT B1OUNDARY is, classified in accrdance with CG EHLHJl...c.alation o tho oM dd bo hb.c.d on pithor .e.ogniio.n

.o.a.... A or C .C. .EAL #1 Basis:E-AL-41This EAL escalates from RAU2 in that the loss of level, in the affected portion of theREFUELING

PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visualobservation (e.g., reports from personnel or camera images),

as well as significant changes in water and radiation levels, or other plant parameters.

Computational aidsmay also be used (e.g., a boil-off curve). Classification of an event using this EAL shouldbe based on the totality of available indications, reports and observations.

While an area radiation monitor could detect aA iieaeerise in a dose rate due to alowering of water level in some portion of the REFUELING

PATHWAY, the reading maynot be a reliable indication of whether or not the fuel is actually uncovered.

To the degreepossible, readings should be considered in combination with other available indications ofinventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 Basis:EAL-#2This EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly.

A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of apotential fuel damaging event (e.g., a fuel handling accident).

Month 20XXTMI 3-14EP-AA-1009 (Revision XX)

I::xelon Nucl@arThrop Mile~ Island Staition Annex Exelon NuceianrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency would be based on either Recognition Category R A-or CEA #3Spent fuel pool water level at this value ir, within the low,,er And of the level rangeneccary to prevent significant dose conseguoncos from direct gamma radiation toperconnel performing eperations in the V.icinity Of the cpent fuel peel. This conditoreflects a significant loss Of spcnt fuol pool water inventor; and thus it. is alsoRa a precursor two t .. *f tt V 7 w 5m ra ,- 7 c5 q5

  • W !C-- ---s ,^ -----t- ,Esclatonof the emorgnonc Gla6ification leveXl wo.AUld be via I~s A8i Or A82 f(se ASD v.,l,.rr Aot,).Basis Reference(s):
1. NEI 99-01 Rev 6, AA22. Operating Procedure OP-TM-MAP-C0105 RCS Draindown LVL HI/LO3. OP-TM-MAP-CO101, Radiation Level HI4. UFSAR, Section 14.2.2.1

-"Fuel Handling Accident" 5 Technical Specification 3.8.11 (Reactor Cavity Level)6. Operating Procedure OP 1101-2.1 Radiation Monitoring System Setpoints Month 20XXTMI 3-15EP-AA-1009 (Revision XX)

N.cIAarThro* wisw kthand Stamtion Annexv EvAnn TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARU2Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:

1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):/i4 x I IKlDI AKllII r-wl l A in=,nI ;r% +km OCh C lII I l In-_ DAT1IfAIAV

\'/k.~. AKN -; 6"-n n~n.,.,.i iýi i i F iz a-- ...........

-(Site G~ecific loeve'l indicatiens).

AkINI.A.ND--1 1- -A as%* 9 1-~r.I S *I 1 ~ U U* III L4* L4 S L4U~tI~5 U

  • Y~U ~A US SASSA~ flSU U 5 ti 5u=fowfeiwn Faife lnenfter
  • (sitospocif ic list of aroa radi-ation monitor)1. a. UNPLANNED water level drop in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R2.Table R2Radiation MonitorsRMS Area Monitored ModeRM-G-9 FHB Bridge Rad Monitor ALLRM-G-6 RB Auxiliary Bridge Rad Monitor 5,6RM-G-7 RB Main Bridge Rad Monitor 5, 6Basis:UNPLANNED:

A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.Month 20XXTMI 3-16EP-AA-1009 (Revision XX)

NuclearThree Mile Island Staition Annex Exelnn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS REFUELING PATHWAY:

all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a deGrease-loss in water level above irradiated fuel sufficient to causeelevated radiation levels. This condition could be a precursor to a more serious eventand is also indicative of a minor loss in the ability to control radiation levels within theplant. It is therefore a potential degradation in the level of safety of the plant.I A water level deGrease-loss will be primarily determined by indications from available levelinstrumentation.

Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) or fromany other temporarily installed monitoring instrumentation.

A significant drop in the waterlevel may also cause an inRGeaserise in the radiation levels of adjacent areas that can bedetected by monitors in those locations.

The effects of planned evolutions should be considered.

For example, a refueling bridgearea radiation monitor reading may iGFreaserise due to planned evolutions such as liftingof the reactor vessel head or movement of a fuel assembly.

Note that this EAL isapplicable only in cases where the elevated reading is due to an UNPLANNED loss ofwater level.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):

1. NEI 99-01 Rev 6, AU22. UFSAR, Section 14.2.2.1

-"Fuel Handling Accident"

3. OP-TM-MAP-CO105 RCS Draindown
4. OP 1202-12, Excessive Radiation Levels5. OP 1101-2.1 Radiation Monitoring System Setpoints
6. Technical Specification 3.8.11 (Reactor Cavity Level)Month 20XXTMI 3-17EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA3Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability:

1,2,3,4,5,6, DEmergency Action Level (EAL):Note: If the equipment in the listed-room or area listed in Table R4 was alreadyinoperable, or out of service, before the event occurred, then no emergency classification is warranted (1) Dooe Fate gr.ator than, 15 in ANY of the ar.as. :* Control Roomw9 (other- site speeitie afeas~r-eefn) fO~t An~ UKINIDIAWNIRfl Aumth mra.u, Or, *n mlotrr' levels that anrihibet OF irneedc aGcrns ta ~ S I.~ *11I 4a II a..a.r.n rI y. .h* main a. am flmaa% as.I J IV T ViV 5i VI Vi IIVIt VI Ill KVVVVV tV__. -----J I--vvIEI I I R I iisitelsoeGG isi t or plant rooms orareas wutn enir: roiatoa moac avvilcaHl)lty l1. Dose rate QreateF than> 15 mR/hr in ANY of the areas contained in Table R3:Table R3Areas Requiring Continuous Occupancy

  • Main Control Room* Central Alarm Station -(by survey)ORMonth 20XXTMI 3-18EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to any of the following Table R4 plant rooms or areas:Table R4Areas with Entrv Related Mode Aplicability Area Entry Related ModeApplicability Reactor Building*

Modes 4, 5. and 6Intermediate Building*

Modes 4. 5. and 6Auxiliary Building*

Modes 4. 5, and 6Fuel Handling Bujildng*

Modes 4. 5. and 6*Areas required to establish shutdown coolingBasis:UNPLANNED:

A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantprocedures--maintain normal plant .p..atin, Or to pcftm a normal plant cooldown andsh'Jtdo-n.

As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.

Table R4 is a list of plant rooms or areas with entry-related mode applicability that containequipment which reguire a manual/local action necessary to transition the plant fromnormal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling),

where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.

This Table does not includerooms or areas for which entry is reguired solely to perform actions of an administrative orrecord keeping nature (e.g., normal rounds or routine inspections).

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and the elevatedradiation levels preclude the ability to place shutdown cooling in serviccat tho tome of theclevated radiation le:ecl. The emergency classification is not contingent upon whetherentry is actually necessary at the time of the increased radiation levels. Access should beconsidered as impeded if extraordinary measures are necessary to facilitate entry ofMonth 20XXTMI 3-19EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS personnel into the affected room/area (e.g., installing temporary shielding beyond thatrequired by procedures, requiring use of non-routine protective equipment, requesting anextension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the time ofthe elevated radiation levels).

For example, the plant is in Mode 1 when the radiation iP,-easerise occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room orarea (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections).

" The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category BA, Cor F ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, AA32. FSAR Section 5.01 Class I Structures, Components, and Systems3. OP-TM-MAP-CO101, Radiation Level HIMonth 20XXTMI 3-20EP-AA-1009 (Revision XX)

Throm Milo lalanrl Qtafinn AnnoyFyislnn NurnlparTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):ran a.l .n a a ran*n.. *k nn ia~v,* ^;*;* S,,l1, -I -~'-I....... * ..... r:~ mni 3~I~I IfOICTO~Tf3T rnc~o colan aciv~y .mio i oraTo ma ail k! !; ;+ of I A I -r k ; i Q ;f; +; n.....-j-- ------------..- ...--...Ct %7vrct W M OPWID CY ri V0 ri out F7%70 %7= 17 17-1. Letdown Monitor RM-L-1 alert alarm (high or low channel).

OR2. Sample analysis indicates that:a. Dose Equivalent 1-131 specific coolant activity

> 60.0 uCVgm.ORb. Dose Equivalent XE-133 specific coolant activity>

797.0 uCi/lm.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications.

This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel claddegradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of adegradation of fuel clad integrity.

An Unusual Event is only warranted when actual fuel clad damage is the cause of theelevated coolant sample activity (as determined by laboratory confirmation).

Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category BA ICs.Month 20XXTMI 3-21EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NEI 99-01 Rev 6, SU32. Operating Procedure 1101-2.1 Radiation Monitoring System Setpoints
3. FSAR Section 11.4.4, Liquid Monitoring Subsystem
4. OP-TM-MAP-C0101, Radiation Level HI5. Technical Specifications 3.1.4, Reactor Coolant System ActivityMonth 20XXTMI 3-22EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FG1Initiating Condition:

Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-23EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FS1Initiating Condition:

Loss or Potential Loss of ANY two barriers.

Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-24EP-AA-1009 (Revision XX)

Thrao M~iId Wcandl Qtatinn AnnoyI=:talnn Nhlo irlrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FA1Initiating Condition:

ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier.

Unlike the Containment

barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.

Note that the loss or potential loss ofContainment barrier in combination with loss or potential loss of either Fuel Cladding orRCS barrier results in declaration of a Site Area Emergency under EAL FS1.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-25EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC1Initiating Condition:

RCS or SG Tube LeakageOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSSA. RCSloactor v~eseol leveol less than (site spccific value).1. RCITS hot leg instruments indicate 0 inches after lowering trend.AND2. In-core thermocouples are unavailable.

AND3. ALL RCP's are secured.Basis:There is no Loss threshold associated with ROS or SG Tube Leakage.Potential Loss Threshold Basis:This reading indicates a reduction in reactor vessel water level sufficient to allow theonset of heat-induced cladding damage.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. FSAR 7.3.2.2.c.

10.d3. OP-TM-EOP-008, RCS Superheated

4. OP-TM-EOP-010, Emergency Procedure Rules Guides and GraphsMonth 20XXTMI 3-26EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC2Initiating Condition:

Inadequate Heat RemovalOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSSA. Core Exit Them~ecouplo readings greater than (site sepoific temper-ature value)1. Tcad > 1400°FPotential LossA. Co re exit thorMOcouplo reading s greater than (site sepocfic temperature value).d k;!;#I~~t

.f n4%nv -4%San,%e

~ A;lt*i A k~ (.4rn~. ^S- ------aIn .... .%"ry ry V rt r. mrtr" ""m "M -Mft- 11"U."U" V5 Ift "cpocific niain)2. > 25°F Superheat OR3. HPI-PORV Cooling in effect--r--,# * ....Basis
Loss Threshold
  1. 1 BasisL~es&-2-A ThisFeadmig-ilndicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.Potential Loss Threshold
  1. 2 BasisPotential Loes 2.A.

temperatures within the core are sufficient to allow the onset ofheat-induced cladding damage.Potential Loss Threshold

  1. 3 Basis L ,,os [2BThis condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier.

In accordance with EOPs, theremay be unusual accident conditions during which operators intentionally reduce theMonth 20XXTMI 3-27EP-AA-1009 (Revision XX)

NuclearThree Mile Island Station Annex Exellon NuclasrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold isI identical to RCS Barrier RC2 Potential Loss threshold-2-A; both will be met. Thiscondition warrants a Site Area Emergency declaration because inadequate RCS heatI removal may result in fuel heat-up sufficient to damage the cladding and inireaseraise RCS pressure to the point where mass will be lost from the system.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. OS-24 Attachment D3. OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer4. OP-TM-EOP-008, RCS Superheated
5. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs6. OS-24, Conduct of Operations during Abnormal and Emergency EventsMonth 20XXTMI 3-28EP-AA-1009 (Revision XX)

Thrdam Uilm lainnel tatinn AnnoyI=Yplnn NnnlanrTkraa Mum IcImnrI ~tmtinn Ann.v Fv.Inn NuIr~IsrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC3Initiating Condition:

Containment Radiation

/ RCS ActivityOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSS1A. Containment radiation monitor roading grcatc. than (site epcific valuc)(RM-G-22 or RM-G-23) reading > 1.95E+03 R/hr.OR?8. (Sitoe-pocific indications that roactOr coolant activ.ity is groator than 300uGi'gm dose equivalent 1 131) Coolant activity as sampled > 300uCi/gm Dose Equivalent 1-131Basis:Loss Threshold

  1. 1 BasisLess4-3AThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equals300jiCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greaterthan that expected for iodine spikes and corresponds to an approximate range of 2% to5% fuel clad damage. Since this condition indicates that a significant amount of fuelclad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCSBarrier RC3 Loss Tthreshold

&A-since it indicates a loss of both the Fuel Clad Barrierand the RCS Barrier.

Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

Loss Threshold

  1. 2 BasisThis threshold indicates that RCS radioactivity concentration is greater than 300 RCi/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete.

Nonetheless, asample-related threshold is included as a backup to other indications Month 20XXTMI 3-29EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION There is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity

/Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-MAP-CO101, Radiation Level HI3. FSAR Section 11.4.4, Liquid Monitoring System Description
4. Calculation C3640-98-034, Prediction of the Response of RM-G-6 and 7 to FuelDamage5. Core Damage Assessment Methodology (CDAM)Month 20XXTMI 3-30EP-AA-1 009 (Revision XX) hrAmAm Uila lalonrl Qtafinn AnnovF:yalnn N"~lAarTkra~ Mum I@kanrl ~t~tinn Anninv Fvmlnn M.mr~I~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC56Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSS1_A. Any condition in the opinion of the Emergency Director that indicates Loss of theFuel Clad Barrier.POTENTIAL LOSS2A. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.Basis:Loss Threshold

  1. 1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold
  1. 2 BasisPotential Los 6. A.AThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-31EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC1Initiating Condition:

RCS or SG Tube LeakageOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSSA-.1 .AA Aautomatic or manual EGGS -(S0)ESAS actuation is required by EITHER of thefollowing:

ag. UNISOLABLE RCS leakageOR!22. Steam Generator tube RUPTURE.POTENTIAL LOSS2. UNISOLABLE RCS leakage > 150,qpm.OR3. HPI-PORV Cooling in effect.OR4. a. RCS Pressure

> 2450 psic.ANDb. RCS Pressure not lowering.

OQperation of a standby charging (makeup) pum Ncrqired by EITHER ofthfollowing.-!.

[- S leakageSG tube leakage.B1. .RCS coldWnr rFate greater than (site pe,;ifi, thermal -hockcicra'imtcdefined by ciGseii indicatienc Month 20XXTMI 3-32EP-AA-1009 (Revision XX)

Throa MUil WaIndl Qtztinn AnnoiyFyalnn NnnlanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION mm *

  • li'A" *3i. I-". !ntO*::ltV

.I.too entr conat....

motIBasis:UNISOLABLE:

An open or breached system line that cannot be isolated, remotely orlocally.RUPTURE(D):

The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety iniection.

FAULTED:

The term aDDlied to a steam aenerator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Loss Threshold

  1. 1 BasisLosse-1AThis threshold is based on an UNISOLABLE RCS leak of sufficient size to require anautomatic or manual actuation of the Emergency Core Cooling System (ECCS). Thiscondition clearly represents a loss of the RCS Barrier.This threshold is applicable to unidentified and pressure boundary
leakage, as well asidentified leakage.

It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location

-inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.

A steam generator with primary-to-secondary leakage of sufficient magnitude to requirea safety injection is considered to be RUPTURED.

If a RUPTURED steam generator isalso FAULTED outside of containment, the declaration escalates to a Site AreaEmergency since the Containment Barrier CT1 Loss threshold 1-A-will also be met.Potential Loss Threshold

  1. 2 BasisPotential Lss 1 .AThis threshold is based on an UNISOLABLE RCS leak that results in the inability tomaintain pressurizer level within specified limits by operation of a normally usedcharging (makeup) pump, but an ECCS (SI) actuation has not occurred.

The threshold is met when an operating procedure, or operating crew supervision, directs that astandby charging (makeup) pump be placed in service to restore and maintainpressurizer level.Month 20XXTMI 3-33EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION This threshold is applicable to unidentified and pressure boundary

leakage, as well asidentified leakage.

It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location

-inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.

If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold CT1 .A-will also be met.Potential Loss Threshold

  1. 3 BasisPatontial I o-.c 1 RThis condition indicates an extreme challenge to the integrity of the RCS pressureboundary due to pressurized thermal shock -a transient that causes rapid RCScooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-002 Loss of 250F Subcooled Margin4. OP-TM-MAP-D031, MU Flow HI5. OP-TM-EOP-005, OTSG Tube LeakageMonth 20XXTMI 3-34EP-AA-1 009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC2Initiating Condition:

Inadequate Heat RemovalOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSSA.HPI-PORV Cooling in effectinadequate ROS ho-at .mo.a. capability

,ia stoam g.n.rato..

as indicated by i;,cpociftcidctoc Basis:There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisPotential Loss 2.-AHPI-PORV Cooling in effect indicates a Lack of Primary to Secondary Heat Transfercapability.

This condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier.

In accordance with EOPs, there may beunusual accident conditions during which operators intentionally reduce the heatremoval capability of the steam generators; during these conditions, classification usingthreshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold isidentical to Fuel Clad Barrier FC2 Potential Loss Tthreshold 2-#8#3; both will be met.This condition warrants a Site Area Emergency declaration because inadequate RCSheat removal may result in fuel heat-up sufficient to damage the cladding andi,,reaseraise RCS pressure to the point where mass will be lost from the system.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-004, Lack of Primary to Secondary Heat TransferMonth 20XXTMI 3-35EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC3Initiating Condition:

Containment Radiation

/ RCS ActivityOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSSA. Containment radiation monitor reading grato, than (RM-G-22 or RM-G-23) reading >25 R/hr.-.(site specific value).Basis:Loss Threshold BasisThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equalsTechnical Specification allowable limits. This value is lower than that specified for FuelClad Barrier FC3 Loss Tthreshold 3-.A#1 since it indicates a loss of the RCS Barrieronly.I There is no RCS Potential Loss threshold associated with RCS Activity

/ Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor ReadingIndicative of Loss of RCS BarrierMonth 20XXTMI 3-36EP-AA-1009 (Revision XX)

IFvnlnn Nudla~rThrais Milp Island Station Annax Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC56Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSSI1_A. Any condition in the opinion of the Emergency Director that indicates Loss of theRCS Barrier.POTENTIAL LOSS2B. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis:Loss Threshold

  1. 1 BasisLsse-&AThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is lost.Potential Loss Threshold
  1. 2 Basis6. A-This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-37EP-AA-1 009 (Revision XX)

Throm Uila lainnei Qtatinn AnnoyF:Yalnn N, nrlanrTurn, MiI~ It6nrl ~tmtinn Ann.v Fv.Inn Mmu~I~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT1Initiating Condition:

RCS or SG Tube LeakageOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSSA. A leaking or RUPTURED SG is FAULTED outside of containment.

1. SG tube leakage > 150prmAND2. SG is FAULTED outside of containment.

Basis:RUPTURE(D):

The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety iniection.

FAULTED:

The term applied to a steam generator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Loss Threshold BasisThis threshold addresses a leaking or RUPTURED Steam Generator (SG) that is alsoFAULTED outside of containment.

The condition of the SG, whether leaking orRUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1Potential Loss Threshold 2.b 4-A and Loss Threshold 1.b-A, respectively.

This condition represents a bypass of the containment barrier.FAULTED is a defined term within the NEI 99-01 methodology; this determination is notnecessarily dependent upon entry into, or diagnostic steps within, an EOP. Forexample, if the pressure in a steam generator is decreasing uncontrollably

[part of theFAULTED definition]

and the faulted steam generator isolation procedure is not enteredbecause EOP user rules are dictating implementation of another procedure to address ahigher priority condition, the steam generator is still considered FAULTED foremergency classification purposes.

The FAULTED criterion establishes an appropriate lower bound on the size of a steamrelease that may require an emergency classification.

Steam releases of this size arereadily observable with normal Control Room indications.

The lower bound for thisaspect of the containment barrier is analogous to the lower bound criteria specified in ICMonth 20XXTMI 3-38EP-AA-1009 (Revision XX)

NuclearThropu MiIA 1-cland Atnatinn Annex Exelnn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION BRSU3 for the fuel clad barrier (i.e., RCS activity values) and IC MSU64 for the RCSbarrier (i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steamgenerator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant andsustained release of radioactive steam to the environment (and are thus similar to aFAULTED condition).

The inability to isolate the steam flow without an adverse effecton plant cooldown meets the intent of a loss of containment.

Steam releases associated with the expected operation of a SG power operated reliefvalve or safety relief valve do not meet the intent of this threshold.

Such releases mayoccur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stablecondition and prepare to initiate a plant cooldown.

Steam releases associated with theunexpected operation of a valve (e.g., a stuck-open safety valve)-dG meets thisthreshold.

Following an SG tube leak or rupture, there may be minor radiological releases througha secondary-side system component (e.g., air ejectors, glad seal exhausters, valvepacking, etc.). These types of releases do not constitute a loss or potential loss ofcontainment but should be evaluated using the Recognition Category BA lCs.The emergency classification levels resulting from primary-to-secondary

leakage, withor without a steam release from the FAULTED SG, are summarized below.Month 20XXTMI 3-39EP-AA-1009 (Revision XX)

Throm Milo Ilainel ~tatinn AnnoyvF:yalnn Nwlona~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Affected SG is FAULTEDOutside of Containment?

P-to-S Leak Rate Yes NoLess than or equal to 25 No classification No classification gpm (Or othor value p. .SUW Do'v.'lepor Notes)Grete thanm 25 gpm (oGreater than 25 gpm(oOth'r v.,alue SU4Greater than 150 aDm.Unusual Event perSU4MU6Unusual Event perSU4MU6The capacity of one makeuppump in the normal Site Area Emergency charging mode is exceeded per FS1Requires operation of-aAlert per FA1pumpo(RCS BarrierPotential Loss)Requires an automatic ormanual EGGS (SI) actuation (RCS Barrier Loss)Site Area Emergency per FS1Alert per FA1There is no Potential Loss threshold associated with RCS or SG Tube Leakage.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-005, OTSG Tube Leakage4. OP-TM-EOP-001, Reactor TripMonth 20XXTMI 3-40EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExellon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT2Initiating Condition:

Inadequate Heat RemovalOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSSA. 1. (Site cpocific critercia forF Antry into core cooling roctoration procoduro)

AND2. RestorFation pmroedure not eftoctiI.oA Within 15 mninue1. Tcad > 1800°FAND2. EOP Restoration procedures not effective in < 15 minutes.Basis:IMMINENT:

The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisPotential Loes 2.A.This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure.

For thiscondition to occur, there must already have been a loss of the RCS Barrier and the FuelClad Barrier.

If implementation of a procedure(s) to restore adequate core cooling is noteffective (successful) within 15 minutes, it is assumed that the event trajectory will likelylead to core melting and a subsequent challenge of the Containment Barrier.The restoration procedure is considered "effective" if core exit thermocouple readingsare decreasing and/or if reactor vessel level is increasing.

Whether or not theprocedure(s) will be effective should be apparent within 15 minutes.

The Emergency Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.

Severe accident analyses (e.g., NUREG-1 150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damagescenarios, and that the likelihood of containment failure is very small in these events.Given this, it is appropriate to provide 15 minutes beyond the required entry point todetermine if procedural actions can reverse the core melt sequence.

Month 20XXTMI 3-41EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-008, RCS Superheated
3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-006, LOCA CooldownMonth 20XXTMI 3-42EP-AA-1 009 (Revision XX)

E~xAlnn NudlanrThrogm RAilas Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT3Initiating Condition:

Containment Radiation

/ RCS ActivityOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSSAX Containment radiation monitor roading gr.ator than (RM-G-22 or RM-G-23) reading >4.40E+03 R/hr.(scite sp.cifc value).Basis:There is no Loss threshold associated with RCS Activity

/ Containment Radiation.

Potential Loss Threshold BasisPotontial Loss 3. AThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that 20% of the fuel cladding has failed.This level of fuel clad failure is well above that used to determine the analogous FuelClad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protective actions.

For this condition to exist, there must already have been a loss of the RCSBarrier and the Fuel Clad Barrier.

It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. Core Damage Assessment Methodology (CDAM)Month 20XXTMI 3-43EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Initiating Condition:

Containment Integrity or BypassOperating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSSCT41A. Containment isolation is required AND EITHER of the following:

a4-. UNPLANNED deGrease-lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Directors judgmentthat indicate a loss of containment integrity.

ORb2. UNISOLABLE pathway from containment to the environment exists.OR28. Indication of RCS leakage outside of containment POTENTIAL LOSSJA nmnerI-Orising.OR48. Explosive mnixtureContainment

> 4%.ORnIY conaiiionS menieacior BuilOing pressure

> 5o pslg andexists inside containment..

Hydrogen Concentration in5G. al-. GentainmeFt-Reactor Building pressure greater than (site spe.ifi; pressuresetp t> 30 osiciANDb2. ILees~ than one full train of (site sepoific.

Syrtcm Or equipment) is operating per deign for 15 "min, ute or longer. Reactor Building Emerqency Cooling is lessthan ANY one of the following conditions.

SPRAY COOLERS2 00 31 1Basis:FAULTED:

The term aDDlied to a steam aenerator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Month 20XXTMI 3-44EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION UNPLANNED:

A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.UNISOLABLE:

An open or breached system line that cannot be isolated, remotely orlocally.LossThreshold

  1. 1 Basis:L-ess-4.These thresholds address a situation where containment isolation is required and one oftwo conditions exists as discussed below. Users are reminded that there may beaccident and release conditions that simultaneously meet both loss thresholds 1.a4--A4and 1.b4.A2.1 .a4 A I -Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referredto as design leakage).

Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop incontainment pressure.

Recognizing the inherent difficulties in determining acontainment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given tocurrent plant conditions, and available operational and radiological data (e.g.,containment

pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).Refer to the middle piping run of Figure 9-F-4. Two simplified examples are provided.

One is leakage from a penetration and the other is leakage from an in-service systemvalve. Depending upon radiation monitor locations and sensitivities, the leakage couldbe detected by any of the four monitors depicted in the figure.Another example would be a loss or potential loss of the RCS barrier, and thesimultaneous occurrence of two FAULTED locations on a steam generator where onefault is located inside containment (e.g., on a steam or feedwater line) and the otheroutside of containment.

In this case, the associated steam line provides a pathway forthe containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment

pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.

Thesereleases do not constitute a loss or potential loss of containment but should beevaluated using the Recognition Category RA ICs.1 -Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment.

As usedhere, the term "environment" includes the atmosphere of a room or area, outside thecontainment, that may, in turn, communicate with the outside-the-plant atmosphere Month 20XXTMI 3-45EP-AA-1009 (Revision XX)

Thrno Wig% Ilainni Qtafinn AnnovFvalnn TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION (e.g., through discharge of a ventilation system or atmospheric leakage).

Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.

Refer to the top piping run of Figure 9-F-4. In this simplified

example, the inboard andoutboard isolation valves remained open after a containment isolation was required (i.e.,containment isolation was not successful).

There is now an UNISOLABLE pathwayfrom the containment to the environment.

The existence of a filter is not considered in the threshold assessment.

Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 9-F-4. In this simplified

example, leakage in anRCP seal cooler is allowing radioactive material to enter the Auxiliary Building.

Theradioactivity would be detected by the Process Monitor.

If there is no leakage from theclosed water cooling system to the Auxiliary

Building, then no threshold has been met.If the pump or system piping developed a leak that allowed steam/water to enter theAuxiliary
Building, then loss threshold 2_4B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the fourmonitors depicted in the figure and cause threshold 1 .a4A4 to be met as well.Following the leakage of RCS mass into containment and a rise in containment
pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.

Minorreleases may also occur if a containment isolation valve(s) fails to close but thecontainment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category RA ICs.The status of the containment barrier during an event involving steam generator tubeleakage is assessed using Containment Barrier CT1 Loss lthreshold-l-A.

Loss Threshold

  1. 2 Basis:L4e66-4.B Containment sump, temperature, pressure and/or radiation levels will inGoeaserise ifreactor coolant mass is leaking into the containment.

If these parameters have notincreased, then the reactor coolant mass may be leaking outside of containment (i.e., acontainment bypass sequence).

IFiGeaseRaises in sump, temperature,

pressure, flowand/or radiation level readings outside of the containment may indicate that the RCSmass is being lost outside of containment.

Month 20XXTMI 3-46EP-AA-1 009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Unexpected elevated readings and alarms on radiation monitors with detectors outsidecontainment should be corroborated with other available indications to confirm that thesource is a loss of RCS mass outside of containment.

If the fuel clad barrier has notbeen lost, radiation monitor readings outside of containment may not inareaserise significantly;

however, other unexpected changes in sump levels, area temperatures orpressures, flow rates, etc. should be sufficient to determine if RCS mass is being lostoutside of the containment.

Refer to the middle piping run of Figure 9-F-4. In this simplified

example, a leak hasoccurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.

Depending upon radiation monitor locations and sensitivities, the leakage could bedetected by any of the four monitors depicted in the figure and cause loss threshold 1 .a4.A-.-

to be met as well.To ensure proper escalation of the emergency classification, the RCS leakage outsideof containment must be related to the mass loss that is causing the RCS Barrier RClLoss Threshold 1.a and/or Potential Loss threshold 2.a-l-A to be met.Potential Loss Threshold

  1. 3 BasisPtentiaI Less 4. AIf containment pressure exceeds the design pressure, there exists a potential to lose theContainment Barrier.

To reach this level, there must be an inadequate core coolingcondition for an extended period of time; therefore, the RCS and Fuel Clad barrierswould already be lost. Thus, this threshold is a discriminator between a Site AreaEmergency and General Emergency since there is now a potential to lose the thirdbarrier.Potential Loss Threshold

  1. 4 BasisPotential Loss 4.1.The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity.

Ittherefore represents a potential loss of the Containment Barrier.Potential Loss Threshold

  1. 5 BasisPotontial L-se 4.GThis threshold describes a condition where containment pressure is greater than thesetpoint at which containment energy (heat) removal systems are designed toautomatically
actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually startequipment that may not have automatically
started, if possible.

This threshold represents a potential loss of containment in that containment heatremoval/depressurization systems (e.g., containment sprays, ice condenser fans, etc.,Month 20XXTMI 3-47EP-AA-1009 (Revision XX)

Throo Milo Icinnel Qtnfinn AnnovF:valnn Iw-la~l rThr~ Miki IQI~nrI ~t~tinn Ann~v Fv~Inn Miir~I~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION but not including containment venting strategies) are either lost or performing in adegraded mannerBasis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. FSAR Section 6.6 Reactor Building Pressure-Time Response3. Technical Specifications 3.5.3, Engineered Safeguards Protection SystemActuation Setpoints
4. FSAR Section 6.3.3, Actuation
5. FSAR Section 6.5.3, Hydrogen Generation
6. OP-TM-EOP-006, LOCA Cooldown7. 1302-5.25 Reactor Building Sump Level8. FSAR Section 5.2 Reactor Building9. FSAR Section 9.2, Chemical Addition and Sampling System10. OP-TM-EOP-002, Loss of 250F Subcooling Margin11. OP-TM-EOP-006, LOCA Cooldown12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs13. OP-TM-MAP-D0301, High Make-up FlowMonth 20XXTMI 3-48EP-AA-1009 (Revision XX)

Tknagi RAHft Id.-AftrvA Q*-m*mon AnniawIvaletn Mmrai lnarIEEE ~ EVIIE~ U~E~E E~4 ~ U I~EEE E~*~ ~~~~U~SU U ***TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT56Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3,4Fission Product Barrier (FPB) Threshold:

LOSS.1A. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSS28. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis:Loss Threshold

  1. 1 BasisLOesS-6This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is lost.Potential Loss Threshold
  1. 2 BasisPotential Loss 6.,AThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-50EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG1Initiating Condition:

Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the General promptlyupon determining that (cite cp-.ifi,"

hou .r,) the applicable time has beenexceeded, or will likely be exceeded.

1--a-. Loss of ALL offsite and ALL , n"it; AC power to (Sit .specific egencybuses)Emeraencv 4KV buses.2.ANDFailure of EG-Y-1 A, EG-Y-11B Emerqency Diesel Generators and EG-Y-4 SBO.Diesel Generator to supply power to Emergency 4KV buses.AND3b. EITHER of the following:

a. Restoration of at least one emer4eRey-Emergency 4KV bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> isthan (site specific hourS) i. n likely.ORb. > 250F superheat p
  • I *Ill m I I It~ite sE~ocmc inaication oran ina~iiitv toaaoeauateiv remove noa;t mrnrom o orc* lJBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or lacin it in the cold shutdown condition, including the ECCS.These aretypically systems classified as safety-related.

This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heatremoval/pressure

control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of oRe rOmoroa ny fission productMonth 20XXTMI 3-51EP-AA-1009 (Revision XX) hrom Wha lalanri tatinn AnnovF::alnn Tkrn~ MiI~ Iokanrl ~hatinn Ann.v FvInn fJmur~I.~ar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS barriers.

In addition, fission product barrier monitoring capabilities may be degradedunder these conditions.

The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. This will allow additional time for implementation of offsiteprotective actions.Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andevent trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.

The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.

Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade.

The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The emergency busses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.

Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):

1. NEI 99-01 Rev 6, SG12. OP-TM-EOP-01 0 Emergency Procedure Rules, Guides And Graphs3. FSAR Section 8.2.2 Unit Distribution System4. FSAR Section 8.2.3 Sources of Auxiliary Power5. FSAR Section 8.5 Station Blackout6. Technical Specification Section 3.7, Unit Electric Power System7. 1107-1 Normal Electrical System8. 1107-2A Emergency Electrical

-4KV and 480 Volt9. OP-TM-AOP-020 Loss Of Station Power10. 1107-3 Diesel Generator

11. 1107-9 SBO Diesel Generator
12. OP-TM-EOP-008 RCS Superheated
13. OS-24, Conduct of Operation during Abnormal and Emergency EventsMonth 20XXTMI 3-52EP-AA-1 009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS1Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Sito Arop E..ergencyevent promptlyupon determining that the applicable time 4-5-inutes-has been exceeded, or willlikely be exceeded.

1. Loss of ALL offsite and ALL ,n-it, AC Power to (;ito ..p.ific oFmo.gon..Y buses)Emergency 4KV buses for 15 minutec Or longR. .AND2. Failure of EG-Y-1A, EG-Y-11B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from thetime of loss of both offsite and onsite AC power.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure

control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions.

This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.The emergency busses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.

Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.Month 20XXTMI 3-53EP-AA-1009 (Revision XX)

Throa Wig% lalanfi Qfafinn AnngvFvalnn .iollarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RAG 1, FG1. e--MSG11or MG2.Basis Reference(s):

1. NEI 99-01 Rev 6, SS12. FSAR Section 8.2.3, Sources of Auxiliary Power3. Technical Specification Section 3.7, Unit Electric Power System4. 1107-1 Normal Electrical System5. 11 07-2A Emergency Electrical

-4KV and 480 Volt6. OP-TM-AOP-020 Loss Of Station Power7. 1107-3 Diesel Generator

8. 1107-9 SBO Diesel Generator
9. FSAR Section 8.2.2, Unit Distribution System10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-54EP-AA-1 009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA1Initiating Condition:

I Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAleFt promptly upondetermining that the applicable time 16 r:inutes-has been exceeded, or will likelybe exceeded.

1.AC power capability to Emergency 4KV buses reduced to only one of the following power sources for > 15 minutes." Auxiliary Transformer 1 A" Auxiliary Transformer 1 B* Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1 B" SBO Diesel Generator EG-Y-4a. AC power vapability' to buses) is reduced to a singl.9ower source for 15 minutes Or longer.AND2b. Any additional single power source failure will result in a loss of all-ALL AC powerto SAFETY SYSTEMS.Basis:SAFETY SYSTEM: A svstem reauired for safe Dlant operation, cooling down the plantand/or Dlacina it in the cold shutdown condition.

includina the ECCS.These areItypically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS.

In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.

This IC provides an escalation path from ICMSUI.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.Month 20XXTMI 3-55EP-AA-1009 (Revision XX) hrgaia Wha lalanA Qtatinn AnnovP::ainn Throo Milo IeIonrI Qtoti,~n Annoy Fv~Inn NmIr~I~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS e A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).

e A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.

9 A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MSS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA12. FSAR Section 8.2.3, Sources of Auxiliary Power3. FSAR Section 8.5, Station Blackout4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical

-4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator

9. 1107-9 SBO Diesel Generator
10. FSAR Section 8.2.2, Unit Distribution SystemMonth 20XXTMI 3-56EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU1Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual E'-entevent promptly upondetermining that the applicable time 1-6 Finutes-has been exceeded, or will likelybe exceeded.

1-. Loss of ALL offsite AC power capability to Emergency 4KV buses (site-speGifi emcrgoncy b.. ) , for _> 15 minutes-er-feng.

Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification

purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it.The emergency busses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.

Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MSA1.Basis Reference(s):

1. NEI 99-01 Rev 6, SUW2. FSAR Section 8.2.3, Sources of Auxiliary Power3. Technical Specification Section 3.7, Unit Electric Power System4. 1107-1 Normal Electrical System5. 11 07-2A Emergency Electrical

-4KV and 480 Volt6. OP-TM-AOP-020 Loss Of Station Power7. 1107-3 Diesel Generator

8. 1107-9 SBO Diesel Generator Month 20XXTMI 3-57EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS

9. FSAR Section 8.2.2, Unit Distribution SystemMonth 20XXTMI 3-58EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG28Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Genoral ,, ,.,-ge..yevent promptlyupon determining that the applicable time 46-eninutes-has been exceeded, or willlikely be exceeded.

1. Loss of ALL offsite AC power to Emerqency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emerqency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Voltage is < 105 VDC on1 25 VDC Distribution System 1 A and 1 B.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1. a. Los o _6ef ALL-'-e of 6it. a:;n di A LL onsite AG power to (eitc specific omergeFncy

-buses) for 15 mninutes or longer-.ANDb. Indicated voltage is less than (site-specific bus voltage value) onAL(site sp;cific; Vital D- busses) for 15 r Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretvpicallv systems classified as safetv-related.

Month 20XXTMI 3-59EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heatremoval/pressure

control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS.

Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.

Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when beth-allEALs thleshelds-are met.Basis Reference(s):

1. NEI 99-01 Rev 6, SG82. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System Failure6. FSAR Section 8.2.2, Unit Distribution System7. FSAR Section 8.2.3, Sources of Auxiliary Power8. Technical Specification Section 3.7, Unit Electric Power System9. 1107-1 Normal Electrical System10. 11 07-2A Emergency Electrical

-4KV and 480 Volt11. OP-TM-AOP-020 Loss Of Station Power12. 1107-3 Diesel Generator

13. 1107-9 SBO Diesel Generator
14. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-60EP-AA-1009 (Revision XX) krAmg% Rfiligh lalonA Ctotinn AnniavIPvgmlen khaot--mar lkm~ I ll a WI QVliruil B "IlIAn a vninM lar*U1 *1U *usu ,. uu. flu ul. ll Iut.I.I..I TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS28Initiating Condition:

Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Aroa Em...ge..yevent promptlyupon determining that the applicable time 45-inutes--has been exceeded, or willlikely be exceeded.

vVoltage is < 105 VDC loss than (site spocific b.us125 VDC Distribution System 1A and 11B ALL (sit -sp'. .fiG ">15 minutes-er-IGRleF.

Ivoltage value)- novital DG bussee4 forBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitorand control SAFETY SYSTEMS.

In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient losses.Escalation of the emergency classification level would be viaMSG3.or momentary powerICs RAG1, FG1 orBasis Reference(s):

1. NEI 99-01 Rev 6, SS82. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System FailureMonth 20XXTMI 3-61EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS36Initiating Condition:

Inability to shutdown the reactor causing a challenge to core cooling or RCS heatremoval.Operating Mode Applicability:

1,2Emergency Action Level (EAL):1. Automatic or Manual Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. All-ALL manual actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 5%.AND3. EITHER of the following conditions exist:a. Tclad > 14000F.ORb. HPI-PORV Cooling in effect-.fl!A...a. cakeO sDCCITI indirtcaliiun of an inability to adequately rumuve nueat irumA Me GOrci--" \ ..... r ......-4' --1 ....... jORL.. / ','1-. laiw eciiic~m inudaiurime of aR nauniw it touueuateiv Fefflve i4A--4 'rUNM I.-lII IBasis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, all subsequent operator manual actions,both inside and outside the Control Room including driving in control rods and boroniniection~all operator to mnaually shutdown the areunsuccessful, and continued power generation is challenging the capability toadequately remove heat from the core and/or the RCS. This condition will lead to fuelMonth 20XXTMI 3-62EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS damage if additional mitigation actions are unsuccessful and thus warrants thedeclaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may behigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs.

This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor.

The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Escalation of the emergency classification level would be via IC RAG1 or FGI.Basis Reference(s):

1. NEI 99-01 Rev 6, SS52. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer3. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-001, Reactor Trip5. 1102-4 Power Operation
6. OP-TM-641

-000- Reactor Protection System (RPS/DSS)

Month 20XXTMI 3-63EP-AA-1 009 (Revision XX)

Throp Milo haland qtatinn AnnoyThre Mil I~Iunr ~tiatin Annv Feinn NuclesarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA36Initiating Condition:

Automatic or manual trip fails to shutdown the reactor, and subsequent manual actionstaken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.

1. A.-aAutomatic OF-manual[Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. Manual actions taken at the r.a.tO. cOntrol'

.onsolConsole Center-are notsuccessful in shutting down the reactor as indicated by Reactor Power > 5%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic Omanalreactor trip that results in a reactor shutdown, and subsequent operator manual actionstaken at the Console Center roactor control concolo to shutdown the reactor are alsounsuccessful.

This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor controlconsoles since this event entails a significant failure of the RPS.A manual action at the Console Center reactOr contro! coco!oc is any operator action,or set of actions, which causes the control rods to be rapidly inserted into the core (e.g.,initiating a manual reactor trip. This action does not include manually driving in controlrods or implementation of boron injection strategies.

If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away fromthe Console Center reactor control conGelos (e.g., locally opening breakers).

Actionstaken at back-panels or other locations within the Control Room, or any location outsidethe Control Room, are not considered to be "at the Console Centerro.acto controlGOR60Gee6".

The plant response to the failure of an automatic eF manual-reactor trip will vary basedupon several factors including the reactor power level prior to the event, availability ofthe condenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If the failure to shutdown the reactor is prolonged enough to cause achallenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XXTMI 3-64EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclea~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS I classification level will escalate to a Site Area Emergency via IC MSS_3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. AbsentI the plant conditions needed to meet either IC MSS36 or FS1, an Alert declaration isappropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.

I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA52. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer3. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-001, Reactor Trip5. 1102-4 Power Operation
6. OP-TM-641-000-Reactor Protection System (RPS/DSS)

Month 20XXTMI 3-65EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU36Initiating Condition:

Automatic or manual trip fails to shutdown the reactor.Operating Mode Applicability:

1,2Emergency Action Level (EAL):I Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.

1.a. Ar,-aAutomatic Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.ANDb. A-sSubsequent manual action taken at the rcactOr control concolocConsole Center is successful in shutting down the reactor.ORa. A-fAManual Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2.b. EITHER of the followingt

--J. ..... A----I ..... I---- ;---i- uDaseuentl manual aciion taken at -R murasaar cnuolm.-

cn-nniec I-S ! ; t, 14SUEPE785 u " 6 utt "iq OWR Me FeaSIONOR2. A sSubsequent automatic Ttrip is successful in shutting down thereactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, and either a subsequent operator manualMonth 20XXTMI 3-66EP-AA-1009 (Revision XX)

Throm Mu.la li.nnri Qtafin AnnoyF:valnn Nain-loar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS action taken at the Console Center reactor control consoles or an automatic trip issuccessful in shutting down the reactor.

This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor trip, operators will promptly initiate manualactions at the Console Center reactor control consolos to shutdown the reactor (e.g.,initiate a manual reactor trip). If these manual actions are successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.EAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly tako.n uaaction at anotherl c-ation(s) on the reactor control consoles to shutdown the '.roct.(n._-._ initiato a man,-al macfor trio a diffcrmnt c,;.tch\..

D ..n...ina..

un.........n.

c.v.r.f...........

, .... ,.,....-

..-.-. .--.... ... -----.......-

÷-; --.-....'.c concurren plantIfactors, tho initial or subsequent eeffot to manually trip the roactOr, or a concurrent plantcondition, may lead to the generation of an automatic reactor trip signal. If asubsequent manul- OF automatic trip is successful in shutting down the reactor, coreheat generation will quickly fall to a level within the capabilities of the plant's decay heatremoval systems.A manual action at the Console Center rcactOr control consolSG is any operator action,or set of actions, which causes the control rods to be rapidly inserted into the core (e.g.,initiating a manual reactor trip). This action does not include manually driving in controlrods or implementation of boron injection strategies.

Actions taken at back-panels orother locations within the Control Room, or any location outside the Control Room, arenot considered to be "at the Console Center reactor control consoles".

The plant response to the failure of an automatic or manual reactor trip will vary basedupon several factors including the reactor power level prior to the event, availability ofthe condenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If subsequent operator manual actions taken at the Console Centerreactor control consolcs are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC M.A36. Depending uponthe plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MSA36 or FA1, an Unusual Event declaration is appropriate for this event.I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

I Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpointtesting),

the following classification guidance should be applied.Month 20XXTMI 3-67EP-AA-1009 (Revision XX)

Throp Milo Inland qtafinn AnnpvThrg~ M~ci ~I~d ~mtin An~'tExellnn Nuclea~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS

" If the signal generated as a result of plant work causes a plant transient that createda real condition that should have included an automatic reactor trip and the RPS failsto automatically shutdown the reactor, then this IC and the EALs are applicable, andshould be evaluated.

" If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS trip signal and the trip failure is determined throughother means (e.g., assessment of test results),

then this IC and the EALs are notapplicable and no classification is warranted.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU52. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-001, Reactor Trip4. 1102-4 Power Operation
5. OP-TM-641

-000- Reactor Protection System (RPS/DSS)

Month 20XXTMI 3-68EP-AA-1009 (Revision XX)

Throm Uila lainnel Qtatinn AnnoyF::alnn NiiIe-lar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA42Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.

Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAled promptly upondetermining that the applicable time 45-*i utes-has been exceeded, or will likelybe exceeded.

1. a. AR,-UNPLANNED event results in the inability to monitor ANYone 9o MorTable Mlf t4he followi.ng parameters from within the Control Room for >15minutes O.lenge .r[,,e t.able belo-w][ PA[R parameter list;Reactor PowerRGS LeveiRCS PressureIn Corc/Corc ExitT-empeatufe Table M1 Control Room Parameters

" Reactor Power" PZR Level" RCS Pressure* In Core/Core Exit Temperature

" Level in at least one OTSG" OTSG Emergency Feed Water FlowLev.'Io in a t I es (site specif icnumber) steam; ge-nerators Steam GeneratorAuxiliary orEneCem e Fee mooC A'A ,at F low.ANDb. Any Table M2Wf the transient eveRts in progress.

0 Is^rv% ^ ^ lft iif r11% ft, r ^r trmrr"!%

r ft-e-r IA .Ar- 4..4Ia l,.4 -n..~.4a.

+k.. Or-O/ ..11 1 6A ! !,~ lA.... r ......ReaeWF4p ot 'a" gro -- r .. .--I -.UM W. "- "- .70 Ct toct0 RO:Tii;i "I"Month 20XXTMI 3-69EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Table M2 Significant Transients

" Automatic Turbine Runback >25% thermalreactor power" Electrical Load Rejection

>25% full electrical load" Reactor Trip" ESAS Actuation

" Thermal Power oscillations

> 10%Basis:UNPLANNED:

A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced.

It thus represents a potential substantial degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for ono Or moroany ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s).

For example, the reactor power level cannot be determined from anyanalog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required.

The event would be reported if itsignificantly impaired the capability to perform emergency assessments.

In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective actiondecision-making.

Month 20XXTMI 3-70EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS I This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity

control, core cooling and RCS heat removal.

The loss ofI the ability to determine one o Fnor-anv of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.

InI addition, if all indication sources for one OF or-eany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2Month 20XXTMI 3-71EP-AA-1 009 (Revision XX)

IExelon NuclearThree Mile Islamnd S~tation Annex Exelon NucleanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU42Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Unu-'-ual Evcntcvent promptly upondetermining that the applicable time been exceeded, or will likelybe exceeded.

a- A-UNPLANNED event results in the inability to monitor one OrFmoMr ANY Table M1parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters

" Reactor Power* RCS Level" RCS Pressure" In Core/Core Exit Temperature

  • Level in at least one OTSG.* OTSG Emeraency Feed Water Flow1. of the following Darametercs from within the Contro!1 Room for 15 minutocOF 4OAgef.Month 20XXTMI 3-72EP-AA-1009 (Revision XX)

Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Month 20XXTMI 3-73EP-AA-1009 (Revision XX)

I=xelon NuclearThr~a Milp 11--aland Station Annex Exelnn NucleIAar TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Basis:UNPLANNED:

A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.I As used in this EAL, an "inability to monitor" means that values for one Or morangy ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s).

For example, the reactor power level cannot be determined from anyanalog, digital and recorder source within the Control Room.I An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required.

The event would be reported if itsignificantly impaired the capability to perform emergency assessments.

In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective actiondecision-making.

I This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity

control, core cooling and RCS heat removal.

The loss ofthe ability to determine one O mer-eany of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.

InI addition, if all indication sources for one Or morany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.

I Escalation of the emergency classification level would be via IC MSA42.Month 20XXTMI 3-74EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, SU2Month 20XXTMI 3-75EP-AA-1009 (Revision XX)

ExAIon NuclearThrpp Mile Island Stsation Annaex Exelon Nucle~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA59Initiating Condition:

I Hazardous event affecting a SAFETY SYSTEM needd -required for the currentoperating mode.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):( .1-.a The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)

" Internal or external flooding event" High winds or tornado strike" FIRE* EXPLOSION

-(,ito ,p ,,ific haza, dc)* Other events with similar hazard characteristics as determined by theShift ManagerANDEITHER of the following:

a.4, Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed-required byTechnical Specifications for the current operating mode.ORb.. 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure-neededrequired by Technical Specifications for the current operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if larqe quantities of smoke and heat areobserved.

EXPLOSION:

A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization.

A release of steam (from highenerav lines or comoonents) or an electrical comoonent failure (caused bv short circuits.

grounding.

arcing, etc.) should not automatically be considered an explosion.

SuchMonth 20XXTMI 3-76EP-AA-1009 (Revision XX)

Three Mile Islaind Stsatio~n Annex Exellon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the EGOS. These aretypically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements,

testing, or analysis.

The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, needed-required for the currentoperating mode, "required",

i.e. required to be operable by Technical Specifications forthe current operating mode. This condition significantly reduces the margin to a loss orpotential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety eguipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL 4402.a BasisThis EAL addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is in since indications for it will be readily available.

The indications ofdegraded performance should be significant enough to cause concern regarding theoperability or reliability of the SAFETY SYSTEM train.EAL 1.b.2 2.b BasisThis EAL addresses damage to a SAFETY SYSTEM component that is- required to beoperable by Technical Specifications for the current operating mode, and is not inse wlee/operation or readily apparent through indications alone, of-as well as damage toa structure containing SAFETY SYSTEM components.

Operators will make thisdetermination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RASI.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):

1. NEI 99-01, Rev 6 SA9Month 20XXTMI 3-77EP-AA-1009 (Revision XX)

Throm Uila lalanel Atatinn Annowl::p~lnn N~nlaarThin. Mu. IQhanrI ~t~tinn Ann.v Fvp inn Niir~Iisnr TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU64Initiating Condition:

RCS leakage for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptly upondetermining that the applicable time 1456 -intes-has been exceeded, or will likelybe exceeded.

1. RCS unidentified or pressure boundary leakage gieateF-than

> 10 gpm for > 15 minutes.

(cito spcificvalue) for 15 minutoc Or longer-.OR2. RCS identified leakage >eateF thaR->25 gpm for>

.uFfor 15 .9Finutes or longer.OR3. Leakage from the RCS to a location outside containment

>25 gpm for > 15 minutes.groator than 25 gpmR for 15 minutes Or longer.Basis:UNISOLABLE:

An open or breached system line that cannot be isolated, remotely orlocally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 BasisThese EALs are focused on a loss of mass from the RCS due to "unidentified leakage",

"pressure boundary leakage" or "identified leakage" (as these leakage types are definedin the plant Technical Specifications).

EAL #3 BasisThis EAL addresses a RCS mass loss caused by an UNISOLABLE leak through aninterfacing system.These EALs thus apply to leakage into the containment, a secondary-side system (e.g.,steam generator tube leakage) or a location outside of containment.

Month 20XXTMI 3-78EP-AA-1009 (Revision XX)

ExAIon NuclearThreea Mile Island Station Annex Exelon NuclanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.

Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).

EAL #1 uses a lower valuethat reflects the greater significance of unidentified or pressure boundary leakage.The release of mass from the RCS due to the as-designed/expected operation of arelief valve does not warrant an emergency classification.

An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning asdesigned/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).

The 15-minute threshold duration allows sufficient time for prompt operator actions toisolate the leakage, if possible.

Escalation of the emergency classification level would be via lCs of Recognition Category RA or F.Basis Reference(s):

1. NEI 99-01 Rev 6, SU42. OP-TM-220-251 RCS Leak Rate Determination
3. OP-TM-220-252, Primary -To -Secondary Leakrate Determination
4. OP-TM-PRF1-0405 RB Sump Level HI5. UFSAR 6.4.3, Bases of Leakage Estimate6. UFSAR 6.4.4, Design Basis Leakage7. OP-TM-AOP-050, Reactor Coolant Leakage8. Technical Specification 3.1.6, Leakage and Table 4.1-2, Minimum Equipment Test Frequency Month 20XXTMI 3-79EP-AA-1009 (Revision XX)
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